_ ...Aft.. CORPORATE DIVISION 2026. Legal | Regulatory | Corporate Social Investment Government Support & Relations | Corporate Secretary. 

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Legal | Regulatory | Corporate Social Investment Government Support & Relations | Corporate Secretary

OVERVIEW. CONTENTS. 01. LEGAL. Case resolved, legal and commercial contracts, advisory & compliance services and future roadmap. 

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Case resolved, legal and commercial contracts,  advisory & compliance services and future roadmap

Regulatory compliance, SIM and Spectrum acquisition, License  (new and renewal), Pricing standards (CAP), consumer protection and competition management

Corporate Social responsibility, sustainability & empowerment

Law enforcement coordination & service provision, National Security Compliance

stakeholder Management, Stakeholder engagement, Compliance with legal requirements, communication and Clearances, permits

Governance, compliance & group, board  and shareholder support

01. LEGAL. Major case closures, advisory services & 2026 compliance roadmap. 

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Major case closures, advisory services & 2026 compliance roadmap

LEGAL. REGULATORY. CSI. GOVT SUPPORT. GOVT RELATIONS. 

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Original Amount KDR 4 Sites AIBAK Claim 1M Penalty 48000 111500 1000000 Amount Saved KDR 4 Sites AIBAK Claim 1M Penalty 48000 67500 1000000

■ KDR 4 Sites: $48K saved ■ AIBAK: reduced from $111.5K to $44K ■ AFN 1M penalty case resolved - ATRA ■ Service providers disputes resolved ■ Multiple vendor settlements ■ Employee claims advisory ■ Tax & Labor law compliance ■ Regulatory counsel provided

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Agreements (Technical, IT, finance and S&D)

■ THR (029)/NGR (035) Sites- dispute resolved ■ Agreements processed: 85 from various divisions ■ Lease Agreements finalized : 146 ■ EBU (Corporate SIM+ SMS & Call routing +ISP) agreements :26  ■ NDA finalized: 12  ■ Active and backbone  support to the other operational department in various issues (Tax etc.)

High value contracts – finalized (Huawei, I Engineering, LATRO, BMB, Mobile Tech.)

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■ Centralized system — no independent lawmaking bodies  ■ Theocracy- Religiously dominant decision-making  ■ Legal uncertainty + Arbitrary decision-making  ■ Fragile constitutional framework (unpredictable laws) ■ Sanctions & banking compliance ■ Property & land disputes (uncertain mechanism)  ■ Employment regulatory uncertainty- keep changes  ■ Gov restrictions on agreements- obtain clarence from the law enforcement agencies

Follow up all pending court cases — timely submissions, evidence gathering & strategic representation

Power of Attorneys for certain senior staff for ATOMA representation

compliance with laws, regulations, rulings & government directives to ensure business stability

shutterstock.com • 2707021935. 02. REGULATORY. SIM acquisition, spectrum licenses & ATRA compliance. 

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SIM acquisition, spectrum licenses & ATRA compliance

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1.05M SIMs Acquired | 140 MHz Spectrum Secured

New SIMs Q1 2026 Q2 2026 400 400 Swap SIMs Q1 2026 Q2 2026 100 150

■ 10% increase in SIM swap allocations (inQ2) ■ 6 GHz band to increase Backbone sites aptitude ■ Network coverage significantly expanded ■ Regulator deadlines met (Statistical reports and payment)  ■ QoS drive test logs reviewed (QoS KIP discussed – to reduce threshold) ■ SIM re-registration oversight and report to the regulator  ■ Problematic SIMs (Physical SIM issue + easy access to subscribers) ■ ERP & International top-up (in progress)  ■ TDF Proposal (single sources – site construction)  ■ Smart Chat Portal approved

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Regulatory approval obtained for Smart Chat Portal platform, enabling enhanced customer engagement and digital communication.

ATRA-approved payment plan improves cash flow while maintaining full regulatory compliance.

✓ Ensured regulatory requirements ✓ Regulatory deadlines achieved ✓ Drive test logs reviewed ✓ QoS standards maintained ✓ ISPC codes processed ✓ Advocacy efforts

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■ Spectrum renewals ■ MTS license extension ■ ISP compliance ■ BTS authorizations ■ ATRA deadlines to attain

■ Microwave link licenses ■ ISPC code processing ■ Short code allocations ■ SMS identifiers ■ Annual Frequency Fee ■ TDF + TSF  ■ Statistical reports (required to be submitted quarterly- Financial/HR/ Commercial/ IT /NW and Corporate- Reports)

■ ATRA coordination ■ New SIM approvals ■ Swap SIM inventory (info to be shared with ATRA)  ■ Market demand alignment ■ Adequate stock levels

03. CORPORATE SOCIAL INVESTMENT. Community impact, sustainability & youth empowerment. 

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Community impact, sustainability & youth empowerment

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1,000 Relief Packages | 3,500 Trees | 400 Scholarships

Earthquake victims in Kunar province — food, shelter & medical aid

Across three regions + computer lab for 350 orphans

Educational advancement & vocational training nationwide

"At ATOMA, sustainable business success goes hand in hand with meaningful social impact and community empowerment."

Orphans with Digital Access/ computer Lab

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11.75M AFN CSI Investment Plan in 2026 (Q 3-4)

value Vocational Training Relief Packages Women's Handcraft Blood Donation 5.88 4.1100000000000003 1.47 0.29399999999999998

400 scholarships for youth skill development & employment readiness

Relief Packages for IDPs & Disaster Victims

Emergency support for displaced persons & natural disaster communities

250 women empowered through vocational skills for economic independence

Community health initiative promoting voluntary blood donation

M;uiü'. 04. GOVERNMENT SUPPORT. Law enforcement coordination, clearances & permits. 

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Law enforcement coordination, clearances & permits

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35,000+ Cases Handled | Trusted Law Enforcement Partner

Strong collaborative relationships maintained across all operational regions. Seamless coordination and mutual support for security-related matters.

■ Data privacy vs law enforcement requests ■ Reputation management on sensitive cases ■ Emergency request rapid response ■ Documentation & compliance verification

■ Trusted partner positioning ■ Timely response framework ■ Proactive stakeholder engagement ■ Data compliance excellence

M;uiü'. 04. GOVERNMENT RELATIONS. Law enforcement coordination, clearances & permits. 

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439 Work Permits | 165+ Employees Cleared

■ 16 employees awaiting security clearance ■ 32 suppliers pending approval ■ 1 expatriate clearance in progress

■ Visa & work permits for expatriates ■ Regulatory framework alignment ■ Stakeholder management and engagement + Advocacy  ■ Proactive risk mitigation

■ Delays in approvals & clearances ■ Nationality restrictions on hiring ■ Verbal guidance creates uncertainty ■ Compressed compliance deadlines ■ Limited documented procedures

Stakeholder engagement, managements , advocacy and distribution of Eid gifts to 200+

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Corporate Secretary | Governance Framework

■ Track decisions & ensure implementation ■ Maintain official records

■ Manage communications with Group, shareholder and Board  ■ Maintain shareholder records ■ Process resolutions

■ Ensure company law compliance ■ Maintain statutory registers ■ Timely corporate disclosures ■ Governance code adherence

■ Advise CEO on governance risks ■ Support strategic transactions ■ Restructuring guidance ■ managing internal & external communication

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strengthen risk management frameworks, case closures and prevent future disputes.

Maintain ATRA relationships to secure timely approvals and favorable terms for spectrum and licensing.

Align 11.75M AFN CSI investments with community needs to maximize social return and brand reputation.

Implement digital tracking and dedicated liaison channels to reduce approval turnaround times.

Continue strong governance practices through the Corporate Secretary's compliance and documentation framework. Policy review, Authority Matrix and organizational restructuring

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_ ...Aft.. THANK YOU. ATOMA Corporate Division. 

ATOMA Board Report 2026 - Legal & Regulatory Progress

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