Kaspi.kz (KSPI) director shifts 17,778 ADSs into family trust

Q: Was the Kaspi.kz (KSPI) Form 4 transaction a market sale or purchase?

The Form 4 shows no market sale or purchase . Instead, it records a bona fide gift of 17,778 ADSs, transferred for no consideration from direct ownership into a family trust, changing only how the holdings are structured and reported.

Q: How many Kaspi.kz (KSPI) ADSs did the director move into the trust?

The director transferred 17,778 American Depositary Shares (ADSs) into a trust on April 2, 2026. Each ADS represents one common share of Kaspi.kz, so the transaction effectively reclassified 17,778 common-share equivalents into indirect ownership.

Q: Does the Kaspi.kz (KSPI) director retain economic interest after gifting the ADSs?

Yes. Although the 17,778 ADSs were transferred as a bona fide gift to a family trust, the director retains pecuniary interest in those securities. He reports the move as a shift from direct to indirect ownership and disclaims beneficial ownership beyond that interest.

Q: What does the Kaspi.kz (KSPI) Form 4 say about beneficial ownership?

The Form 4 notes the director disclaims beneficial ownership of the ADSs held by the trust, except to the extent of his pecuniary interest. This clarifies that his reported position reflects economic exposure rather than full beneficial control over the transferred shares.

Filing Impact

(Neutral)

Filing Sentiment

(Neutral)

Form Type

Rhea-AI Filing Summary

Joint Stock Co Kaspi.kz director Szymon Gutkowski reported a non-market transfer of 17,778 American Depositary Shares (ADSs) on April 2, 2026. Each ADS represents one common share. He made a bona fide gift transfer for no consideration from his direct holdings to a trust.

The trust is one where he is the settlor and his immediate family members are the sole beneficiaries. He retains pecuniary interest in the 17,778 ADSs now held indirectly through the trust and therefore reports this as a change from direct to indirect ownership while disclaiming beneficial ownership beyond his economic interest.

Insider Trade Summary

35,556 shares gifted

Mixed 2 txns

Insider Gutkowski Szymon

Role Director

Type	Security	Shares	Price	Value
Gift	American Depositary Shares, no par value	17,778	$0.00	--
Gift	American Depositary Shares, no par value	17,778	$0.00	--

Holdings After Transaction: American Depositary Shares, no par value — 0 shares (Direct); American Depositary Shares, no par value — 17,778 shares (Indirect, By trust)

Footnotes (1)

Each American Depositary Share (ADS) represents one common share of the issuer. On April 2, 2026, the reporting person transferred 17,778 ADSs for no consideration to a trust of which he is the settlor and of which his immediate family members are the sole beneficiaries. The reporting person retains pecuniary interest in the securities held by the trust and thus is reporting the transaction as a change from direct ownership to indirect ownership. The reporting person disclaims beneficial ownership of such securities, except to the extent of his pecuniary interest therein.

Key Figures

ADSs transferred: 17,778 ADSs Post-transaction direct holdings: 0 ADSs Post-transaction indirect holdings: 17,778 ADSs +2 more

5 metrics

ADSs transferred 17,778 ADSs Bona fide gift on April 2, 2026

Post-transaction direct holdings 0 ADSs Direct ownership after gift transfer

Post-transaction indirect holdings 17,778 ADSs Held by trust after reclassification

Transaction price per share $0.00 Gift transfer for no consideration

ADS to share ratio 1 ADS = 1 common share Equivalence stated in filing footnote

Key Terms

American Depositary Share (ADS), bona fide gift, pecuniary interest, indirect ownership, +1 more

5 terms

bona fide gift financial

"transaction_code_description: Bona fide gift"

pecuniary interest financial

"The reporting person retains pecuniary interest in the securities held by the trust"

indirect ownership financial

"reporting the transaction as a change from direct ownership to indirect ownership"

beneficial ownership financial

"The reporting person disclaims beneficial ownership of such securities"

Beneficial ownership means the person or entity that actually enjoys the benefits of owning shares or other assets — such as receiving dividends, voting rights, or price gains — even if the legal title is held in another name. For investors it matters because knowing who truly controls and profits from a company reveals who can influence decisions, exposes potential conflicts of interest or hidden concentration of power, and affects transparency and risk in the stock.

Form 4 Insider Transactions: What Each Field Means →

04/06/2026 - 04:15 PM

SEC Form 4

FORM 4

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

STATEMENT OF CHANGES IN BENEFICIAL OWNERSHIP

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:			3235-0287
Estimated average burden
hours per response:			0.5

Check this box if no longer subject to Section 16. Form 4 or Form 5 obligations may continue. See Instruction 1(b).

Check this box to indicate that a transaction was made pursuant to a contract, instruction or written plan for the purchase or sale of equity securities of the issuer that is intended to satisfy the affirmative defense conditions of Rule 10b5-1(c). See Instruction 10.

1. Name and Address of Reporting Person^*

Gutkowski Szymon

(Last)

(First)

(Middle)

154A NAURYZBAI BATYR STREET

(Street)

ALMATY

050013

(City)

(State)

(Zip)

KAZAKSTAN

(Country)

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

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

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

2a. Foreign Trading Symbol

3. Date of Earliest Transaction (Month/Day/Year)
04/02/2026

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

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

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

Table I - Non-Derivative Securities Acquired, Disposed of, or Beneficially Owned
1. Title of Security (Instr. 3)	2. Transaction Date (Month/Day/Year)	2A. Deemed Execution Date, if any (Month/Day/Year)	3. Transaction Code (Instr. 8)		4. Securities Acquired (A) or Disposed Of (D) (Instr. 3, 4 and 5)			5. Amount of Securities Beneficially Owned Following Reported Transaction(s) (Instr. 3 and 4)	6. Ownership Form: Direct (D) or Indirect (I) (Instr. 4)	7. Nature of Indirect Beneficial Ownership (Instr. 4)
1. Title of Security (Instr. 3)	2. Transaction Date (Month/Day/Year)	2A. Deemed Execution Date, if any (Month/Day/Year)	Code	V	Amount	(A) or (D)	Price		6. Ownership Form: Direct (D) or Indirect (I) (Instr. 4)	7. Nature of Indirect Beneficial Ownership (Instr. 4)

Table II - Derivative Securities Acquired, Disposed of, or Beneficially Owned (e.g., puts, calls, warrants, options, convertible securities)
1. Title of Derivative Security (Instr. 3)	2. Conversion or Exercise Price of Derivative Security	3. Transaction Date (Month/Day/Year)	3A. Deemed Execution Date, if any (Month/Day/Year)	4. Transaction Code (Instr. 8)		5. Number of Derivative Securities Acquired (A) or Disposed of (D) (Instr. 3, 4 and 5)		6. Date Exercisable and Expiration Date (Month/Day/Year)		7. Title and Amount of Securities Underlying Derivative Security (Instr. 3 and 4)		8. Price of Derivative Security (Instr. 5)	9. Number of derivative Securities Beneficially Owned Following Reported Transaction(s) (Instr. 4)	10. Ownership Form: Direct (D) or Indirect (I) (Instr. 4)	11. Nature of Indirect Beneficial Ownership (Instr. 4)
1. Title of Derivative Security (Instr. 3)	2. Conversion or Exercise Price of Derivative Security	3. Transaction Date (Month/Day/Year)	3A. Deemed Execution Date, if any (Month/Day/Year)	Code	V	(A)	(D)	Date Exercisable	Expiration Date	Title	Amount or Number of Shares	8. Price of Derivative Security (Instr. 5)		10. Ownership Form: Direct (D) or Indirect (I) (Instr. 4)	11. Nature of Indirect Beneficial Ownership (Instr. 4)
American Depositary Shares, no par value	⁽¹⁾	04/02/2026		G⁽²⁾			17,778	⁽¹⁾	⁽¹⁾	American Depositary Shares, no par value	⁽¹⁾	$0	0	D
American Depositary Shares, no par value	⁽¹⁾	04/02/2026		G⁽²⁾		17,778		⁽¹⁾	⁽¹⁾	American Depositary Shares, no par value	⁽¹⁾	$0	17,778	I	By trust

Explanation of Responses:

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

2. On April 2, 2026, the reporting person transferred 17,778 ADSs for no consideration to a trust of which he is the settlor and of which his immediate family members are the sole beneficiaries. The reporting person retains pecuniary interest in the securities held by the trust and thus is reporting the transaction as a change from direct ownership to indirect ownership. The reporting person disclaims beneficial ownership of such securities, except to the extent of his pecuniary interest therein.

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.

	/s/ Yuri Didenko, as attorney-in-fact for Szymon Gutkowski	04/06/2026
	** 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 4 (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 4: SEC 1474 (03-26)

Source: View Original Filing on SEC EDGAR

FAQ

What insider transaction did Kaspi.kz (KSPI) disclose for Szymon Gutkowski?

Kaspi.kz director Szymon Gutkowski reported a bona fide gift transfer of 17,778 American Depositary Shares (ADSs) on April 2, 2026. The transaction moved shares from his direct ownership into a trust structure associated with his immediate family members.

Was the Kaspi.kz (KSPI) Form 4 transaction a market sale or purchase?

The Form 4 shows no market sale or purchase. Instead, it records a bona fide gift of 17,778 ADSs, transferred for no consideration from direct ownership into a family trust, changing only how the holdings are structured and reported.

How many Kaspi.kz (KSPI) ADSs did the director move into the trust?

The director transferred 17,778 American Depositary Shares (ADSs) into a trust on April 2, 2026. Each ADS represents one common share of Kaspi.kz, so the transaction effectively reclassified 17,778 common-share equivalents into indirect ownership.

What is the nature of the trust holding Kaspi.kz (KSPI) ADSs?

The trust receiving the 17,778 ADSs is one where the director is the settlor and his immediate family members are the sole beneficiaries. He retains pecuniary interest in the trust’s Kaspi.kz securities despite the change from direct to indirect ownership.

Does the Kaspi.kz (KSPI) director retain economic interest after gifting the ADSs?

Yes. Although the 17,778 ADSs were transferred as a bona fide gift to a family trust, the director retains pecuniary interest in those securities. He reports the move as a shift from direct to indirect ownership and disclaims beneficial ownership beyond that interest.

What does the Kaspi.kz (KSPI) Form 4 say about beneficial ownership?

The Form 4 notes the director disclaims beneficial ownership of the ADSs held by the trust, except to the extent of his pecuniary interest. This clarifies that his reported position reflects economic exposure rather than full beneficial control over the transferred shares.