GENTRACK GROUP LIMITED — Regulatory Filings 2025

Mar 30, 2025

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WGN

AKL

Level 1 Level 15 11 Cable Street 45 Queen Street Wellington 6011 Auckland 1010 New Zealand New Zealand PO Box 2959 PO Box 106 555 P +64 4 472 7599 P +64 9 368 1375

28 March 2025

Ms Anna Ellis Company Secretary Gentrack Group Limited By email: anna.ellis@gentrack.com

Dear Ms Ellis,

Gentrack Group Limited (GTK) – Price Enquiry

We write with respect to the continuous disclosure obligations set out in the Listing Rules ( Rules ). Listing Rule 3.1.1 ( the rule ) is set out in the Schedule attached to this letter. In summary, this rule requires issuers to promptly and without delay disclose any Material Information to the market through NZX’s market announcement platform ( MAP ). The rule provides limited exceptions to this obligation. Material Information does not need to be disclosed where a reasonable person would not expect the information to be disclosed and where the information is confidential, and its confidentiality is maintained and where one of five safe harbours applies.

The price of GTK is up just over 10% on the day as I write.

Given this increase in the price, please advise NZ RegCo whether GTK continues to comply with Listing Rule 3.1.1.

We would appreciate it if you could provide NZ RegCo with an answer to the above question (email: surveillance@nzregco.com) before 9:00 am Monday, 31 March 2025.

Please provide your response to this letter in “PDF” format, and note that it will be published in full to the market.

Kind Regards,

Phil Solarz Head of Surveillance

NZ RegCo Surveillance

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SCHEDULE

3.1 Disclosure of Material Information

• 3.1.1 Once an issuer becomes Aware of any Material Information relating to it, the Issuer must: a) Promptly and without delay release that Material Information through MAP, and

• b) Not disclose any Material Information to the public, any other stock exchanges (except as provided for in Rule 3.26.2(d)) or any other party without first releasing that Material Information through MAP.

• 3.1.2 Rule 3.1.1 does not apply when:

• (a) One or more of the following applies:

  • i) Release of the information would be a breach of the law,

  • ii) The information concerns an incomplete proposal or negotiation,

  • iii) The information contains matters of supposition or is insufficiently definite to warrant disclosure

  • iv) The information is generated for internal management purposes, or

  • v) The information is a trade secret,

• (b) The information is confidential and its confidentiality is maintained, and

• (c) A reasonable person would not expect the information to be disclosed.

3.2 False Market

• 3.2.1 An Issuer must promptly and without delay release Material Information through MAP to the extent necessary to prevent development or subsistence of a market for its Quoted Financial Products which is materially influenced by false or misleading information emanating from:

• a. the Issuer or any Associated Person of the Issuer, or

• b. other persons in circumstances in each case which would give such information substantial credibility,

and which is of a reasonably specific nature whether or not Rule 3.1.2 applies.

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Gentrack Group Ltd

17 Hargreaves Street, St Marys Bay Auckland 1011, PO Box 3288, Auckland 1140, New Zealand Ph: +64 9 966 6090 Email: info@gentrack.com www.gentrack.com

31 March 2025

Attention: Mr Phil Solarz Head of Surveillance NZ RegCo Surveillance

Response to NZ RegCo Price Enquiry issued 28 March 2025

Gentrack Group Limited (GTK) confirms that, as at the date of this response, it continues to comply with its continuous disclosure obligations under NZX Listing Rule 3.1.1.

ENDS

For further information please contact:

John Priggen Chief Financial Officer Gentrack Group Limited