EMBELTON LIMITED — Major Shareholding Notification 2004

Nov 3, 2004

Facsimile Transmission

Tolhurst Noall
Share Brokers & Financial Planners

	TO: ASX COMpany Drnew amounts
Company:
Fax:	$\rightarrow \rightarrow$ 1900 999279
	From: $R.Hayeww$
	Contact: 03 9 242 4 007
Email:
	Date: $\left\langle \mathbf{q} \right\rangle \left\langle \mathbf{i} \right\rangle$ , $\Delta v_{\mathbf{q}}$
No. of Pages:

GERALDTON
38 Marine Terrace
Geraldton
WA 6530
Tel: (08) 9964 3800
Fax: (08) 9964 5811

Eevel 14
90 King William St
Adelalde SA 5000
Tel: (08) 8407 5700
Fax: (08) 8407 5717

MELBOURNE $L$ avel 29 35 Collins Street Melbourne Vic 3000
Tel: (03) 9242 4000
Fax: (03) 9242 4040

SYDNEY Level 35 cover 33
60 Margaret Street
Sydney NSW 2000 Tel: (02) 9247 8886
Fax: (02) 9247 8386

PERTH Level 30

---------
44 St. George's Toe
Ferth WA 6000
Tel: (08) 9268 4888 Fex: (08) 9268 4884 ADELAIDE Level 14

÷.

MOUNT WAVERLEY
284 Stephensons Rd
Mount Waverley Victoria 3149 Tel: (03) 9831 5000 Fax: (03) 9809 5746

ARMADALE 1201 High Street Armadale Victoria 3143 Tel: (03) 8823 6666
Fax: (03) 8823 6699

MAROOCHYDORE Level 3

26 Duporth Ave

Marcochydore

Queensland 4556

Tel: (07) 5409 6400

Tel: (07) 5409 6400 Fax: (07) 5409 6199

$\mathop{\mathsf{f}}\nolimits$

Form 603 Corporations Act 2001
Section 671B

Notice of initial substantial holder

To Company Name/Scheme	Embelton Limited
ACN/ARSN	004 401 496
1. Details of substantial holder (1) Name	Charmof Nominees Pty Ltd
ACN/ARSN (if applicable)	004 862 604
The holder became a substantial holder on	29/10/04
2. Details of 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 on the date the substantial holder became a substantial holder are as follows:

Class of securities (4)	. Number of securities ___	--------------------------------------- Person's votes (5)	Voting power (6)
ORD ---	145.784 ----	145.784	6.76%
. __		_ . _______	---------------------------------------

3. Details of relevant interests

The nature of the relevant interest the substantial holder or an associate had in the following voting securities on the date the substantial holder became a substantial holder are as follows:

. Holder of relevant interest -----	Nature of relevant interest (7)	Class and number of securities
Charmof Nominees Pty Ltd $-11 - 11$	Registered holder of Shares	145.784 ORD ----
Mrs Chadotte Moffatt	Beneficial Owner of Shares	145,784 ORD

4. Details of present registered holders

The persons registered as holders of the securities referred to in paragraph 3 above are as follows:

$\frac{1}{2}$

Holder of relevant Inlarest	Registered holder of Securities	Person entitled to be registered as holder (8)	Class and number of securities
Mrs Charlotte Moffatt ----	Charmof Nominees Pty Ltd	Mrs Charlotte Moffatt	145 784 ORD

5. Consideration

The consideration paid for each relevant interest referred to in paragraph 3 above, and acquired in the four months prior to the day that the substantial holder became a substantial holder is as follows:

Holder of relevant Inlerest	Date of acquisition	Consideration (9)	Class and number of securities
Charmof Nominees Pty Ltd	29/10/04	\$467.791.70	145.784 ORD
	__

6. Associates

The reasons the persons named in paragraph 3 above are associates of the substantial holder are as follows:

Name and ACN/ARSN (if applicable)	Nature of association
------------------ _________ -------	_ ______

7. Addresses

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

Name	Address
Charmol Nominees Pty Ltd .	1151 Rathdowne Street Carlton . .
-----

Signature

	print name MR GORDON MOFFATT --------------------------------------- --------	capacity	DIRECTOR
sign here		Date

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 7 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 total number of votes attached to all the voting shares in the company or voting interests in the scheme (if any) that the person or an associate has a relevant interest in.
• $(6)$ The person's votes divided by the total votes in the body corporate or scheme multiplied by 100.
• $(7)$ Include details of:
• any relevant agreement or other circumstances by which the relevant interest was acquired. If subsection 671B(4) applies, a copy of any $(a)$ document setting out the terms of any relevant agreement, and a statement by the person giving full and accurate details of any contract. scheme or arrangement, must accompany this form, together with a written statement certifying this contract, scheme or arrangement; and
• $(5)$ any qualification of the power of a person to exercise, control the exercise of, or influence the oxercise of, the voting powers or disposal of the securities to which the relevant interest rolatos (indicating clearly the particular securities to which the qualification applies).

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

$\cdot$

• (8) If the substantial holder is unable to determine the identity of the person (eg. if the relovant interest arises because of an option) write "unknown."
• $(9)$ Details of the consideration must include any and all benefits, moneys and other, that any person from whom a relevant interest was acquired has, or may, become entitled to receive in relation to that acquisition. Details must be included oven 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.