Climate Change Data

Environmental Metrics

Climate Goals & Targets

Environmental Challenges

• The outbreak of the COVID-19 pandemic impacted and will likely continue to impact the global economy, global financial markets and our business which may have a material adverse effect on our business, financial condition and results of operations.

Mitigation Strategies

• In response to local COVID-19 related restrictions, a significant percentage of our employees have transitioned to working remotely. For those functions that cannot be performed remotely, we have implemented a number of measures to maintain the health and safety of our employees and customers, including reducing the hours our bank branch offices are open, meeting with customers only by appointment, limiting customer interaction to functions that cannot be performed remotely, limiting non-essential travel, cancelling in-person work-related meetings, and temperature screening.

Supply Chain Management

Climate-Related Risks & Opportunities

Environmental Metrics

Climate Goals & Targets

Environmental Challenges

• Delays in the electronic filing process that resulted in the report filing not being accepted by the Securities and Exchange Commission’s Edgar filing system until after the 5:30 pm Eastern time filing deadline.

Mitigation Strategies

• The annual report on Form 10-K will be filed immediately following the filing of this Form 12b-25, which will be within fifteen calendar days of the date the original report was due.

Supply Chain Management

Climate-Related Risks & Opportunities

Environmental Metrics

ESG Focus Areas

• Humanitarian relief efforts
• Green bonds underwriting
• Financial literacy education

Environmental Achievements

• Underwriting of Eurasian Development Bank bonds used to finance ESG projects in Kazakhstan

Social Achievements

• Contributed nearly $3,000,000 to humanitarian relief efforts in Ukraine
• Launched Freedom Finance Academy providing free financial literacy courses
• Launched Freedom Finance Camp for Kazakhstan school children on financial education

Governance Achievements

• Not disclosed

Climate Goals & Targets

Environmental Challenges

• Russia/Ukraine Conflict and related sanctions
• Economic sanctions limiting fund movement and access to capital markets
• Inability to complete divestiture of Russian subsidiaries
• Economic and political conditions in operating regions
• Heightened risks from Russian operations due to sanctions and countersanctions

Mitigation Strategies

• Divesting ownership interest in Russian subsidiaries
• Corporate restructuring to transfer ownership of Kazakhstan subsidiaries
• Enhanced due diligence to ensure compliance with sanctions
• Implementing a standardized customer onboarding and monitoring platform (Sum and Substance)

Supply Chain Management

Supplier Audits: Not disclosed

Responsible Procurement

• Not disclosed

Climate-Related Risks & Opportunities

Physical Risks

• Not disclosed

Transition Risks

• Not disclosed

Opportunities

• Not disclosed

Reporting Standards

Frameworks Used: Null

Certifications: Null

Third-party Assurance: Not disclosed

UN Sustainable Development Goals

• Not disclosed

Not disclosed

Sustainable Products & Innovation

• Not disclosed

Awards & Recognition

• Freedom Insurance recognized by Global Banking & Finance Review

Environmental Metrics

Climate Goals & Targets

Environmental Challenges

• Incorrect reporting of certain loans issued and customer liabilities in the consolidated statement of cash flows for prior periods. Specifically, certain loans issued were presented as operating activities (instead of investing activities), and deposits from banking institutions were presented as operating activities (instead of financing activities).

Mitigation Strategies

• The Registrant is currently completing its financial statements as of and for the three months ended September 30, 2022 and is assessing whether the reclassification described above should be applied to the Registrant’s previously issued financial statements.

Supply Chain Management

Climate-Related Risks & Opportunities