Freedom Holding Corp. — Director's Dealing 2025

Feb 20, 2025

SEC Form 4 — Statement of Changes in Beneficial Ownership

Issuer: Freedom Holding Corp. (FRHC)
CIK: 0000924805
Period of Report: 2025-02-14

Reporting Person: Lukyanov Sergey (N/A)

Non-Derivative Transactions

Date	Security	Code	Shares	Price	A/D	Holdings After	Ownership
2025-02-14	Common Stock	S	2901	$160.29	Disposed	124800	Direct
2025-02-18	Common Stock	S	1958	$160.53	Disposed	122842	Direct
2025-02-19	Common Stock	S	2042	$157	Disposed	120800	Direct

Footnotes

F1: Mr. Lukyanov was awarded 106,000 restricted shares of common stock of Freedom Holding Corp. (the "Company") under the Company 2019 Equity Incentive Plan pursuant to that certain Restricted Stock Award Agreement entered into as of May 18, 2021, by and between the Company and Mr. Lukyanov (the "Agreement"). Assuming satisfaction of applicable vesting conditions, which include continuous service with the Company and market price conditions tied to the performance of the Company's common shares, 21,200 shares will vest annually beginning May 18, 2022 through May 18, 2026. Mr. Lukyanov's previously filed Form 3 inadvertently omitted the unvested restricted shares of common stock from Mr. Lukyanov's beneficially owned securities, which are now reflected in this Form 4.

F2: Reflects the weighted average price of sales on February 14, 2025. The shares were sold in multiple transactions at prices ranging from $160.20 to $160.51, inclusive. The reporting person undertakes to provide to Freedom Holding Corp., any security holder of Freedom Holding Corp., or the staff of the Securities and Exchange Commission, upon request, full information regarding the number of shares sold at each separate price within such range.

F3: Reflects the weighted average price of sales on February 18, 2025. The shares were sold in multiple transactions at prices ranging from $160.25 to $160.80, inclusive. The reporting person undertakes to provide to Freedom Holding Corp., any security holder of Freedom Holding Corp., or the staff of the Securities and Exchange Commission, upon request, full information regarding the number of shares sold at each separate price within such range.