External Audit Disproves Short Seller Accusations on Freedom Holding Corp.

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An external audit of the
Kazakhstani diversified financial services company, Freedom Holding Corp.
(NASDAQ: FRHC), initiated by the independent members of its board of directors,
has been completed.

The auditors were tasked with analyzing all accusations
made in a short seller report released by Hindenburg Research in August 2023,
against Freedom Holding Corp.

The short seller report accused Freedom Holding Corp. of allegedly
breaching U.S. sanctions against certain Russian citizens, market manipulation,
making false reports and other wrongdoings – a narrative mainly based on
statements by an anonymous source pretending to be a former employee of the
company.

On the heels of the report, independent members of the
board engaged the services of, Morgan, Lewis & Bockius LLP (Morgan Lewis)
and Forensic Risk Alliance (FRA) to undertake a comprehensive review of all
allegations and provide their findings.

Over the past four months, FRA scrutinized documents, corporate data,
inspected Freedom’s offices in Kazakhstan and Cyprus, as well as interviewed
the company’s senior executives, employees, and external consultants.

Conclusions

Audit findings revealed that allegations against Freedom were highly
selective, ignored important contextual information, and were without proof,
according to the holding’s press release.

As an example, the auditors confirmed
that the growth of the company’s core business has been organic, based on the
actual increase in its client base vs. an alleged manipulation of transaction
number data.

Freedom maintains that it is strictly adherent to all
international sanction regimes and follows rules designed to counter money
laundering.

The external auditors also did not find signs of market manipulation by
the company, whether it be its own stocks and assets or bonds issued by the
Kazakhstan Sustainability Fund, which is part of Freedom’s investment strategy.

In addition, as a part of its ongoing process and procedure improvement
initiative, the company asked the group of external auditors to share any
recommendations they had, many of which are already being implemented by the
Freedom’s management.

An external audit of the
Kazakhstani diversified financial services company, Freedom Holding Corp.
(NASDAQ: FRHC), initiated by the independent members of its board of directors,
has been completed.

The auditors were tasked with analyzing all accusations
made in a short seller report released by Hindenburg Research in August 2023,
against Freedom Holding Corp.

The short seller report accused Freedom Holding Corp. of allegedly
breaching U.S. sanctions against certain Russian citizens, market manipulation,
making false reports and other wrongdoings – a narrative mainly based on
statements by an anonymous source pretending to be a former employee of the
company.

On the heels of the report, independent members of the
board engaged the services of, Morgan, Lewis & Bockius LLP (Morgan Lewis)
and Forensic Risk Alliance (FRA) to undertake a comprehensive review of all
allegations and provide their findings.

Over the past four months, FRA scrutinized documents, corporate data,
inspected Freedom’s offices in Kazakhstan and Cyprus, as well as interviewed
the company’s senior executives, employees, and external consultants.

Conclusions

Audit findings revealed that allegations against Freedom were highly
selective, ignored important contextual information, and were without proof,
according to the holding’s press release.

As an example, the auditors confirmed
that the growth of the company’s core business has been organic, based on the
actual increase in its client base vs. an alleged manipulation of transaction
number data.

Freedom maintains that it is strictly adherent to all
international sanction regimes and follows rules designed to counter money
laundering.

The external auditors also did not find signs of market manipulation by
the company, whether it be its own stocks and assets or bonds issued by the
Kazakhstan Sustainability Fund, which is part of Freedom’s investment strategy.

In addition, as a part of its ongoing process and procedure improvement
initiative, the company asked the group of external auditors to share any
recommendations they had, many of which are already being implemented by the
Freedom’s management.

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