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Adastra Holdings Capital/Financing Update 2021

Nov 17, 2021

44131_rns_2021-11-16_c7a3d5fc-a4dd-46f9-b0c8-b882ec935393.pdf

Capital/Financing Update

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FORM 51‐102F3 MATERIAL CHANGE REPORT

Item 1. Name and Address of Company

Adastra Holdings Ltd. (the “ Company ”) 5451 – 275 Street Langley, BC V4W 3X8

Item 2. Date of Material Change

November 16, 2021

Item 3. News Release

The news release was issued and disseminated via Stockwatch and BayStreet on November 16, 2021 and filed on SEDAR at www.sedar.com.

Item 4. Summary of Material Change

The Company announced a private placement financing (the “ Financing ”) to raise gross proceeds of up to $2,500,000 through issuance of up to 2,631,578 Units (each, a “ Unit ”) at a price of $0.95 per Unit.

Item 5. Full Description of Material Change

5.1 Full Description of Material Change

Each Unit will be comprised of one common share of the Company and one transferrable common share purchase warrant (each, a “ Warrant ”). Each Warrant will entitle the holder thereof to acquire one common share of the Company (each, a “ Warrant Share ”) at a price of $1.00 per Warrant Share until 5:00 p.m. (Vancouver time) three years from the closing of the Financing.

All securities issued in connection with the Financing are subject to a statutory hold period expiring four months and one day after the closing of the Financing. The Financing is strategic and currently only offered to warrantholders holding share purchase warrants with an exercise price of $2.25 (the “ $2.25 Warrants ”). Participation in the Financing is conditional upon such warrantholders entering into a warrant cancellation agreement to cancel the $2.25 Warrants effective on the closing of the Financing.

The Company intends to use the proceeds of the Financing towards inventory and general working capital.

5.2 Disclosure for Restructuring Transactions

Not applicable.

Item 6. Reliance on subsection 7.1(2) of National Instrument 51‐102

Not applicable.

Item 7. Omitted Information

None.

Item 8. Executive Officer

Michael Forbes, President, CEO & Director (Chairman) Telephone: (778) 715‐5011

Item 9. Date of Report

November 16, 2021