KD Kyndryl Holdings, Inc.

“The Company did not design and maintain effective controls regarding the internal investigation, escalation and documentation of complaints made through the Company s reporting hotline and certain other available reporting channels, including with respect to appropriate escalation of certain complaints to the Audit Committee.”

“The Company did not design and maintain effective controls related to the information and communication component of the COSO framework to ensure appropriate communication pertaining to the disclosure process between certain functions within the Company, including the Company s Disclosure Committee and the Chief Executive Officer, as well as with the Audit Committee and the Board.”

“The Company s senior finance executives failed to set an appropriate tone at the top based on the principles associated with the control environment component of the Committee of Sponsoring Organizations of the Treadway Commission s Internal Control Integrated Framework (2013) (the COSO framework ).”

“the Chief Executive Officer and the Chief Financial Officer have concluded that the Company s disclosure controls and procedures were not effective as of September 30, 2026 due to the material weaknesses in internal control over financial reporting described below.”

“In addition, as previously disclosed, the Company identified material weaknesses in internal control over financial reporting. For more information, see Controls and Procedures in Part I, Item 4 in this report.”