Ethical principles

Employees, third parties, business partners, and any other interested parties who become aware of a violation of the Code of Conduct or internal regulations of a company within the Freedom Holding Corp. Group can report their suspicions or facts.

The whistleblower is responsible for the information provided in the inquiry. The report of an alleged violation must be objective and impartial. It should include all significant information (facts) with a basis for concern, as well as provide supporting documents (if available). The submission of deliberately false inquiries is considered a serious violation that could lead to accountability measures in accordance with applicable law: such facts, if containing false information and with grounds in accordance with the law, may be forwarded to law enforcement agencies.

Any employee, counterparty, or other third party who reports in good faith should not fear termination of employment, demotion, refusal of business cooperation, harassment, or other forms of discrimination. However, the whistleblower should not abuse the protection provided to them. The protection provided to the whistleblower during the investigation does not exempt them from disciplinary or other liability for submitting a deliberately false inquiry.

Messages are accepted through the website and application of an independent provider (Whispli). A responsible employee from the Compliance Service of a company within the Freedom Holding Corp. group takes the case for review and oversees the entire review process.

Within 5 working days from the date of receipt of the inquiry, an employee of the Compliance Service decides whether to accept the inquiry for review, leave it without consideration, or reject the inquiry if there are no signs of violation, unethical or dishonest behavior, or if there is insufficient introductory data. The duration of the further review may vary depending on the scale, risk level, new data, and other factors affecting the course of the investigation, but a response to your inquiry will be provided no later than 60 calendar days from the date of receipt of the inquiry.

In anonymous mode, it is impossible to identify the whistleblower's identity. Confidentiality (non-disclosure) of the review and its participants must be ensured at every stage, meaning that if the whistleblower discloses their personal data, it will only be known to a small group of people involved in the review and will not be disclosed to anyone, not even auditors.

Anonymity is guaranteed only if the whistleblower uses the Whispli website or app. When registering a message, you can choose the anonymous mode (disclose your name, email, etc.). Then, you will need to save the link, the assigned username (usually a fun nickname, such as "Happy Zebra"), and password, as further communication with the investigator can continue through a special chat in the app.