Kaspi.kz (KSPI) director Gardner Douglas W reports 5,939 ADS stake

Rhea-AI Filing Summary

Joint Stock Co Kaspi.kz director Gardner Douglas W filed an initial ownership report showing holdings of 5,939 American Depositary Shares held directly. Each ADS represents one common share of the issuer, so this filing simply establishes his equity stake rather than reporting a new trade.

Insider Trade Summary

1 transaction reported

Mixed 1 txn

Insider Gardner Douglas W

Role Director

Type	Security	Shares	Price	Value
holding	American Depositary Shares, no par value	--	--	--

Holdings After Transaction: American Depositary Shares, no par value — 5,939 shares (Direct)

Footnotes (1)

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SEC Form 3

FORM 3

UNITED STATES SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549

INITIAL STATEMENT OF BENEFICIAL OWNERSHIP OF SECURITIES

Filed pursuant to Section 16(a) of the Securities Exchange Act of 1934
or Section 30(h) of the Investment Company Act of 1940

OMB APPROVAL

OMB Number:			3235-0104
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hours per response:			0.5

1. Name and Address of Reporting Person^*

Gardner Douglas W

(Last) (First) (Middle)

154A NAURYZBAI BATYR STREET

(Street)

ALMATY 050013

(City) (State) (Zip)

UNITED STATES

(Country)

2. Date of Event Requiring Statement (Month/Day/Year)
03/18/2026

3. Issuer Name and Ticker or Trading Symbol
Joint Stock Co Kaspi.kz [ KSPI ]

3a. Foreign Trading Symbol

5. If Amendment, Date of Original Filed (Month/Day/Year)

4. Relationship of Reporting Person(s) to Issuer
(Check all applicable)

X	Director		10% Owner
	Officer (give title below)		Other (specify below)

6. Individual or Joint/Group Filing (Check Applicable Line)

X	Form filed by One Reporting Person
	Form filed by More than One Reporting Person

Table I - Non-Derivative Securities Beneficially Owned
1. Title of Security (Instr. 4)	2. Amount of Securities Beneficially Owned (Instr. 4)	3. Ownership Form: Direct (D) or Indirect (I) (Instr. 5)	4. Nature of Indirect Beneficial Ownership (Instr. 5)

Table II - Derivative Securities Beneficially Owned (e.g., puts, calls, warrants, options, convertible securities)
1. Title of Derivative Security (Instr. 4)	2. Date Exercisable and Expiration Date (Month/Day/Year)		3. Title and Amount of Securities Underlying Derivative Security (Instr. 4)		4. Conversion or Exercise Price of Derivative Security	5. Ownership Form: Direct (D) or Indirect (I) (Instr. 5)	6. Nature of Indirect Beneficial Ownership (Instr. 5)
	Date Exercisable	Expiration Date	Title	Amount or Number of Shares
American Depositary Shares, no par value	(1)	(1)	Common shares, no par value	5,939	(1)	D

Explanation of Responses:

1. Each American Depositary Share represents one common share of the issuer.

Remarks:

Due to the issuer's status as a foreign private issuer pursuant to Rule 3a12-3(b) under the Securities Exchange Act of 1934 (the "Act"), the reporting person's transactions in the issuer's equity securities are exempt from Sections 16(b) and 16(c) of the Act. Exhibit 24 - Power of Attorney

	/s/ Yuri Didenko as attorney-in-fact for Douglas Gardner	03/18/2026
	** Signature of Reporting Person	Date
Reminder: Report on a separate line for each class of securities beneficially owned directly or indirectly.
* If the form is filed by more than one reporting person, see Instruction 5 (b)(v).
** Intentional misstatements or omissions of facts constitute Federal Criminal Violations See 18 U.S.C. 1001 and 15 U.S.C. 78ff(a).
Note: File three copies of this Form, one of which must be manually signed. If space is insufficient, see Instruction 6 for procedure.
Persons who respond to the collection of information contained in this form are not required to respond unless the form displays a currently valid OMB Number.
* Form 3: SEC 1473 (03-26)

FAQ

What does Gardner Douglas W report owning in Kaspi.kz (KSPI) on this Form 3?

He reports holding 5,939 American Depositary Shares of Joint Stock Co Kaspi.kz directly. This Form 3 serves as an initial statement of his beneficial ownership as a director, documenting his existing equity position rather than announcing a new market transaction.

Is the Kaspi.kz (KSPI) Form 3 for Gardner Douglas W a buy or sell transaction?

It is not a buy or sell; it is a holding entry. The filing classifies the record as a holding, with transaction direction marked unknown and no reported purchase or sale, so it simply discloses his existing ownership of 5,939 American Depositary Shares.

How many Kaspi.kz (KSPI) American Depositary Shares does the director hold after the reported Form 3?

After the reported position, he holds 5,939 American Depositary Shares directly. The filing also reflects 5,939 underlying common shares associated with these ADS, confirming the size of his stake as recorded in this initial beneficial ownership statement.

What does each Kaspi.kz (KSPI) American Depositary Share represent in the Form 3 filing?

Each American Depositary Share represents one common share of Joint Stock Co Kaspi.kz. This one-to-one relationship is explicitly described in the footnotes, allowing investors to translate the 5,939 ADS position directly into the same number of underlying common shares.

What role does Gardner Douglas W have at Kaspi.kz (KSPI) according to the Form 3?

He is identified as a director of Joint Stock Co Kaspi.kz. The Form 3 indicates his status as a reporting person in that capacity, and the disclosed holdings of 5,939 ADS reflect his beneficial ownership position associated with this board role.

Does the Kaspi.kz (KSPI) Form 3 show any derivative or option positions for Gardner Douglas W?

The data references American Depositary Shares with an exercise price of 0.0000 and 5,939 underlying common shares. This presentation aligns the ADS with their corresponding common shares, but does not describe separate options with a premium-based exercise structure.