IMUGENE LIMITED — Major Shareholding Notification 2004

Nov 24, 2004

Form 603

Corporations Law Section 671B

Notice of initial substantial holder

To	Company Name/Scheme	Imugene Limited
1.	Details of substantial holder(1)
Name		Portfolio Partners Limited and entities in the AVIVA plc Group listed in Schedule 1
	ABN (if applicable)	85 066 081 114
	The holder became a substantial holder on	24/11/2004

$2.$ 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	Persons' votes (5)	Voting power (6)
Ordinary shares	10.649.647	10.649.647	$9.83\%$ *

* Based on issued capital of 108,318,080 fully paid ordinary shares.

$3.$ 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
Portfolio Partners Limited	Power to (or to control) exercise vote and/or dispose of the securities as discretionary investment managers or advisers of superannuation funds. pooled superannuation trusts, managed investment schemes and investment management agreements.	10.649.647
Entities in AVIVA plc Group listed in Schedule 1	Deemed relevant interest under section 608(2) or (3) of Corporations Law. See Schedule 1	10.649.647

Details of present registered holders $\ddot{4}$ .

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

Holder of relevant	Reaistered holder of	Person entitled to be registered as holder	Class and number
interest	securities	(8)	of securities
Refer schedule 2

$\overline{\mathbf{5}}$ . 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 interest	Date of acquisition	Consideration (9)		Class and number of securities
Portfolio Partners Limited and the entities in the CGNU plc Group listed in Schedule 1		Cash	Non-cash	Ordinary fully paid shares
	10/09/2004	$($ \$69,022)		$-168,347$
	13/09/2004	\$324,534		865,423
	14/09/2004	\$337,058		886,995
	04/10/2004	\$94,981		253,893
	05/10/2004	\$16,534		45,929
	06/10/2004	\$61,200		170,000
	15/10/2004	( \$40,450)		$-103,718$
	20/10/2004	( \$41, 600)		-104,000
	21/10/2004	( \$41, 206)		$-101,744$
	26/10/2004	( \$36, 551)		-90,250
	02/11/2004	( \$81, 886)		-202,187
	03/11/2004	( \$200, 943)		-505,195
	04/11/2004	( \$174, 162)		-440,805
	09/11/2004	( \$215,000)		-500,000
	10/11/2004	( \$26, 652)		$-60,000$
	11/11/2004	( \$113, 339)		$-254,754$
	15/11/2004	( \$49, 968)		$-138,801$
	16/11/2004	( \$166, 709)		-454,620
	17/11/2004	( \$16, 791)		-45,380
	18/11/2004	( \$101, 192)		$-273,493$
	19/11/2004	(\$2,979)		$-8,276$
	22/11/2004	( \$395, 776)		-1,198,231
	22/11/2004 (in specie transfer)	\$0		1,480,000
	23/11/2004	( \$338, 640)		-1,020,000
	Grand Total	( \$1,278,560)		$-3,447,561$

Associates $6.$

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

Name and ACN (if applicable)	Nature of association
- Refer Schedule 1	Each is a related body corporate of Portfolio Partners Limited

7. Addresses

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

Name	Address
All entities listed in Schedule 1	o/- Portfolio Partners Limited, Level 4, 530 Collins Street, Melbourne, Victoria, 3000

Signature	print name	Lee-Anne Cashman	Capacity	Company Secretary
	Sign here	$M$ $\sim$	Date	25/11/2004

DIRECTIONS

• If there are a number of substantial holders with similar or related relevant interests (eq. a corporation and its related $(1)$ 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.
• See the definition of 'associate' in section 9 of the Corporations Law. $(2)$
• See the definition of 'relevant interest' in sections 608 and 671B(7) of the Corporations Law. $(3)$

WWWW.UN

• The voting shares of a company constitute one class unless divided into separate classes. ${4}$
• $(5)$ 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.
• The person's votes divided by the total votes in the body corporate or scheme multiplied by 100. $(6)$
• $(7)$ Include details of:
• (a) any relevant agreement or other circumstances by which the relevant interest was acquired. 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 contract, scheme or arrangement, must accompany this form, together with a written statement certifying this contract, scheme or arrangement; and

any qualification of the power of a person to exercise, control the exercise of, or influence the exercise of, the voting $(b)$ 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 Law.

$(8)$ 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) Details of the consideration must include any and all benefits, money 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 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.

$\overline{\phantom{0}}$

SCHEDULE 1

List of entities
Aviva Asset Management Services Pty Ltd 12 074 649	NULIFE Insurance Limited 85 008 406 737
068	NULIS Nominees (Australia) Limited 80 008 515 633
Aviva Australia Holdings Limited 38 095 045 784	NZI Leasing Corporation Pty Limited 97 008 601 116
Aviva Australia Limited 32 006 783 286	Portfolio Partners Limited 85 066 081 114
Aviva Fixed Assets (1) Pty Ltd 64 072 232 154	PPL Super Pty Ltd ACN 081 462 197
Aviva Fixed Assets (2) Pty Ltd 89 092 040 438	PremiumChoice Nominees Pty Limited ACN 098 907 423
Aviva Group Limited 55 071 346 800	Tokara Pty Ltd 87 082 564 261
Aviva Insurance Pty Limited 33 099 736 062	United Premium Funding Pty Limited 91 003 219 065
Aviva Marketing Services Pty Ltd 48 060 534 947	Vynotas Pty. Ltd. 70 007 093 601
Aviva Technology Services Pty Ltd 81 068 812 939	Belves Investments Ltd (New Zealand)
FPI Pty Ltd 38 006 305 700	CFM Holdings Ltd (New Zealand)
Gallagher Lane Pty Ltd 13 060 535 104	CGU Holdings (Australia) Ltd (UK)
General Accident Australia and New Zealand Pty Limited	CGU Insurance plc (UK)
ACN 002 902 847	CGU International Holdings BV (Netherlands)
n-able Pty Ltd 25 003 066 073	CGU International Insurance plc (UK)
Navigator Australia Limited 45 006 302 987	Commercial Union Holdings (France) Ltd (UK)
Navigator Investment Services Australia Pty Ltd 26 007	Commercial Union Holdings (NZ) Ltd (New Zealand)
353 424	Commercial Union International Holdings Ltd (UK)
NIML Limited 52 007 016 186	General Accident Asia - Pacific Ltd (New Zealand)
Norstaff Super Limited ACN 060 563 108	General Accident pic (UK)
Norwich House Melbourne Pty Ltd 30 006 475 029	Hibernian Investment Managers Limited (UK)
Norwich Union Life Australia Limited 34 006 783 295	Scottish Insurance Corporation Ltd (UK)
Norwich Union Superannuation Services Pty Ltd 45 007	The Road Transport and General Insurance Co Ltd (UK)
410 193

SCHEDULE 2

Holder of relevant interests	Registered holder of securities	Person entitled to be registered as holder (8)	Class and number of securities
			Ordinary fully paid shares
Portfolio Partners Limited and the entities listed in Schedule 1	Cogent Nominees Pty Ltd		4,437,446
	JP Morgan Nominees Aust. Limited		1.480.000
	RBC Global Services Australia Nominees Pty Limited		3.543.936
	Westpac Custodian Nominees Limited		1.188.265
	Total		Total 10,649,647