Comvita Limited — Director's Dealing 2021

May 23, 2021

DocuSign Envelope ID: 0F786423-60BB-4311-AC4B-C83819E2A18C

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Ongoing Disclosure Notice

Disclosure of Directors and Senior Managers Relevant Interests Sections 297(2) and 298(2), Financial Markets Conduct Act 2013

To NZX Limited; and Name of listed issuer: Comvita Limited Date this disclosure made: 24-May-21 Date of last disclosure: 25-Sep-20 Director or senior manager giving disclosure Full name(s): David Robert Banfield Name of listed issuer: Comvita Limited Name of related body corporate (if applicable): N/A Position held in listed issuer: CEO Summary of acquisition or disposal of relevant interest (excluding specified derivatives) Class of affected quoted financial products: Ordinary Shares Nature of the affected relevant interest(s): Registered Holder - Ordinary Shares For that relevant interest- 337,488 ordinary shares Number held in class before acquisition or disposal: 505,230 ordinary shares (167,742 held by David Number held in class after acquisition or disposal: Banfield and 337,488 held on behalf of the Daivd and Joy Banfield Trust) David Banfield, Joy Banfield and Julian Donald Current registered holder(s): as trustees for the David and Joy Banfield Trust Registered holder(s) once transfers are registered: David Banfield Details of transactions giving rise to acquisition or disposal Total number of transactions to which notice relates: 2 Details of transactions requiring disclosure- Date of transaction: 21-May-21 167,742 ordinary shares by way of transfer from Nature of transaction: treasury stock and issue of shares Name of any other party or parties to the transaction (if known): Comvita Limited The consideration, expressed in New Zealand dollars, paid or received for the acquisition or disposal. If the consideration was not in cash and cannot be readily by converted into a cash value, describe the consideration: $520,000 Number of financial products to which the transaction related: 167,742 ordinary shares If the issuer has a financial products trading policy that prohibits directors or senior managers from trading during any period without written clearance (a closed period) — include the following details Whether relevant interests were acquired or disposed of during a closed period: No Whether prior written clearance was provided to allow the acquisition or disposal to proceed during the closed period: Date of the prior written clearance (if any):

DocuSign Envelope ID: 0F786423-60BB-4311-AC4B-C83819E2A18C

Summary of other relevant interests after acquisition or disposal:

Class of quoted financial products: Nature of relevant interest: For that relevant interest,- Number held in class: Current registered holder(s):

Unlisted Performance Share Rights, these convert to ordinary shares if certain performance targets are met. Registered Holder - Performance Share Rights 35,494 David Banfield

Certification

I, certify that, to the best of my knowledge and belief, the information contained in this disclosure is correct and that I am duly authorised to make this disclosure by all persons for whom it is made. Signature of director or officer: Date of signature: 21/5/2021 | 17:57 NZST