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COMMS GROUP LTD Major Shareholding Notification 2026

Feb 22, 2026

64618_rns_2026-02-22_b4eed11c-f99c-4bd9-bb95-4bb9837aad82.pdf

Major Shareholding Notification

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NAOS ASSET MANAGEMENT LIMITED ABN 23 107 624 126

Level 34 25 Martin Place Sydney NSW 2000 T (02) 9002 1576 E [email protected] www.naos.com.au

23 February 2026

The Manager Market Announcements Office ASX Limited By email: [email protected]

Dear Sir/Madam,

Comms Group Ltd (ASX:CCG) Notice of change of interests of substantial holder (Form 604)

In accordance with section 671B of the Corporations Act 2001 (Cth), please find attached a Form 604 in relation to shares in Comms Group Limited ACN 619 196 539 (ASX:CCG) lodged on behalf of NAOS Asset Management Limited and Related Parties.

Yours faithfully,

Sebastian Evans Director

page 1/2 15 July 2001

604

Form 604

Corporations Act 2001 Section 671B

Notice of change of interests of substantial holder

To Company Name/ Scheme Comms Group Ltd (ASX:CCG) ACN/ARSN 619 196 539 1. Details of substantial holders(1) Name NAOS Substantial Holders referred to in Annexure A. There was a change in the interests of the substantial holder on 20 / 2 / 2026 The previous notice was given to the company on 18 / 11 / 2025 The previous notice was dated 18 / 11 / 2025

2. Previous and present voting power

The total number of votes attached to all the voting shares in the company or voting interests in the scheme that the substantial holder or an associate (2) had a relevant interest (3) in when last required, and when now required, to give a substantial holding notice to the company or scheme, are as follows:

Class of securities (4) Class of securities (4) Previous notice Previous notice Previous notice Present notice Present notice
Person's votes Voting power (5) Person's votes Voting power (5)
Ordinary Shares 49,200,000 9.22% 57,476,524 10.52%
anges in relevant interests
rs of each change in, or change in the nature of, a relevant interest of the substantial holder or an associate in voting securities of the company
e, since the substantial holder was last required to give a substantial holding notice to the company or scheme are as follows:
Date of Person whose Nature of change (6) Consideration Class and Person's votes
change relevant interest given in relation number of affected
changed to change (7) securities
affected
Refer toAnnexure B.
sent relevant interests
rs of each relevant interest of the substantial holder in voting securities after the change are as follows:
Holder of Registered Person entitled to Nature of Class and Person's votes
relevant holder of be registered as relevant number of
interest securities holder (8) interest (6) securities
Refer toAnnexure C

3. Changes in relevant interests

Particulars of each change in, or change in the nature of, a relevant interest of the substantial holder or an associate in voting securities of the company or scheme, since the substantial holder was last required to give a substantial holding notice to the company or scheme are as follows:

4. Present relevant interests

Particulars of each relevant interest of the substantial holder in voting securities after the change are as follows:

[7834726: 24059925_1]

page 2/2 15 July 2001

604

5. Changes in association

The persons who have become associates (2) of, ceased to be associates of, or have changed the nature of their association (9) with, the substantial holder in relation to voting interests in the company or scheme are as follows:

Name of AC/ARSN (if applicable) Nature of association The addresses of persons named in this form are as follow: Name Address NAOS Substantial Holders c/- Level 34, 25 Martin Place, Sydney NSW 2000

  1. Addresses

The addresses of persons named in this form are as follow:

Signature

print name Sebastian Evans capacity On behalf of the NAOS Substantial Holders sign here date 23 / 2 / 2026

DIRECTIONS

  • (1) If there are a number of substantial holders with similar or related relevant interests (eg. a corporation and its related corporations, or the manager and trustee of an equity trust), the names, could be included in an annexure to the form. If the relevant interests of a group of persons are essentially similar they may be referred to throughout the form as a specifically named group if the membership of each group, with the names and addresses of members is clearly set out in paragraph 6 of the form.

  • (2) See the definition of "associate" in section 9 of the Corporations Act 2001.

  • (3) See the definition of "relevant interest" in sections 608 and 671B(7) of the Corporations Act 2001.

  • (4) The voting shares of a company constitute one class unless divided into separate classes.

  • (5) The person's votes divided by the total votes in the body corporate or scheme multiplied by 100.

  • (6) Include details of:

  • (a) any relevant agreement or other circumstances because of which the change in relevant interest occurred. If subsection 671B(4) applies, a copy of any document setting out the terms of any relevant agreement, and a statement by the person giving full and accurate details of any contact, scheme or arrangement, must accompany this form, together with a written statement certifying this contract, scheme or arrangement; and

  • (b) any qualification of the power of a person to exercise, control the exercise of, or influence the exercise of, the voting powers or disposal of the securities to which the relevant interest relates (indicating clearly the particular securities to which the qualification applies).

See the definition of "relevant agreement" in section 9 of the Corporations Act 2001.

  • Details of the consideration must include any and all benefits, money and other, that any person from whom a relevant interest was

  • (7) acquired has, or may, become entitled to receive in relation to that acquisition. Details must be included even if the benefit is conditional on the happening or not of a contingency. Details must be included of any benefit paid on behalf of the substantial holder or its associate in relation to the acquisitions, even if they are not paid directly to the person from whom the relevant interest was acquired.

  • (8) If the substantial holder is unable to determine the identity of the person (eg. if the relevant interest arises because of an option) write "unknown".

  • (9) Give details, if appropriate, of the present association and any change in that association since the last substantial holding notice.

[7834726: 24059925_1]

ANNEXURE A: Details of Substantial Holder

NAOS Asset Management Limited ACN 107 624 126 (which by reference also includes Sebastian Evans as a substantial holder in his personal capacity as he owns more than 20% of the voting shares in the company) (‘NAOS’) and NAOS Emerging Opportunities Company Limited ACN 161 106 510 (‘NCC’).

ANNEXURE B: Changes in Relevant Interests

Date of
change
Person whose
relevant interest
changed
Nature of change (6) Consideration
given in relation
to change (7)
Class and
number of
securities
affected
Person's votes
affected
23/2/2026 NAOS, NCC On-Market $564,086.16 8,276,524
Ordinary Shares
8,276,524

ANNEXURE C: Present Relevant Interests

Holders of
relevant
interests
Registered
holder of
securities
Person
entitled to be
registered as
holder (8)
Nature of
relevant
interest (6)
Class and
number of
securities
Person's
votes
NAOS, NCC JP Morgan
Nominees
Australia
Limited
('JP Morgan')
NCC NAOS (as Investment Manager of NCC) has
a relevant interest in these shares under
sections 608(1)(b) & (c) of the Corporations
Act as it has the power to exercise or control
the exercise of the right to vote and to
dispose of the shares.
NCC has a relevant interest in these shares
under section 608(2) of the Corporations Act
as it has a beneficial interest in shares
held by JP Morgan and has the power to
control the exercise of votes and disposal
of these shares upon revocation of the
management agreement between NCC
and NAOS as investment manager of NCC.
57,476,524
Ordinary
Shares
10.52%