JATCORP LIMITED — Director's Dealing 2023

Apr 10, 2023

Jatcorp (ASX: JAT), at the forefront of innovative technology servicing the world’s largest retail markets. With a track record of successful product development and distinguished technology. JAT is a leading producer of supplementary food and plant-based products.

11 April 2023

Salvador Caldwell Adviser Listings Compliance ASX Limited By email

Dear Salvador

Jatcorp Limited (‘JAT’): Appendix 3Y – Change of Director’s Interest Notice Query

We refer to your letter dated 6 April 2023 concerning an Appendix 3Y lodged one day late concerning shares purchased on 27 March 2023 ( Relevant Trade ). JAT’s answers to your questions are as follows:

1. Please explain why the Appendix 3Y was lodged late.

A director of JAT, Mr Zhan Wang, has been buying JAT shares on market and regularly advising JAT’s Company Secretary of this as part of his obligations under an agreement with JAT to do so.

He has regularly advised the Company Secretary of trades in batches to enable the lodgement of Appendix 3Y’s in a timely manner, and such lodgements have been occurring. The last Appendix 3Y lodged before the Appendix 3Y the subject of your letter was lodged on 27 March 2023, the same day as the Relevant Trade.

When compiling the most recently lodged Appendix 3Y the Company Secretary erroneously thought that the Relevant Trade had been included in the Appendix 3Y lodged on 27 March 2023 and therefore did not include it in the later Appendix 3Y by mistake. We note that the Relevant Trade was for a relatively small amount of 33,000 shares however JAT takes seriously its obligation to comply with the Listing Rules and sincerely apologises for this error.

2. What arrangements does JAT have in place under Listing Rule 3.19B with its directors to ensure that it is able to meet its disclosure obligations under Listing Rule 3.19A?

JAT has an agreement with directors requiring them to disclose trading in JAT securities, and this has been followed by directors.

3. If the current arrangements are inadequate or not being enforced, what additional steps does JAT intend to take to ensure compliance with Listing Rule 3.19B?

JAT considers that the current arrangements are adequate in that the late lodgement was caused by human error of the Company Secretary which is unlikely to re-occur, not late notification by a director.

Yours sincerely

Oliver Carton Company Secretary

Jatcorp Limited | ABN 31 122 826 242 Suite 306, 521 Toorak Road, Toorak VIC 3142 Phone 03 9090 7592 admin@jatcorp.com | jatcorp.com

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6 April 2023

Mr Oliver Carton Company Secretary Jatcorp Limited 502, 2 Blight Street Sydney NSW 2000

By email

Dear Mr Carton

Jatcorp Limited (‘JAT’): Appendix 3Y – Change of Director’s Interest Notice Query

ASX refers to the following:

1. JAT’s Appendix 3Y lodged on the ASX Market Announcements Platform (‘MAP’) on 4 April 2023 for Mr Zhan Wang (the ‘Notice’);

2. Listing Rule 3.19A which requires an entity to tell ASX the following:

   • 3.19A.1 ‘The notifiable interests of a director of the entity (or in the case of a trust, a director of the responsible entity of the trust) at the following times.

     • On the date that the entity is admitted to the official list.

     • On the date that a director is appointed.

The entity must complete Appendix 3X and give it to ASX no more than 5 business days after the entity’s admission or a director’s appointment.

• 3.19A.2 A change to a notifiable interest of a director of the entity (or in the case of a trust, a director of the responsible entity of the trust) including whether the change occurred during a closed period where prior written clearance was required and, if so, whether prior written clearance was provided. The entity must complete Appendix 3Y and give it to ASX no more than 5 business days after the change occurs.

3.19A.3 The notifiable interests of a director of the entity (or in the case of a trust, a director of the responsible entity of the trust) at the date that the director ceases to be a director. The entity must complete Appendix 3Z and give it to ASX no more than 5 business days after the director ceases to be a director.’

1. Listing rule 3.19B which states that:

‘An entity must make such arrangements as are necessary with a director of the entity (or in the case of a trust, a director of the responsible entity of the trust) to ensure that the director discloses to the entity all the information required by the entity to give ASX completed Appendices 3X, 3Y and 3Z within the time period allowed by listing rule 3.19.A. The entity must enforce the arrangements with the director.’

The Notice indicates that a change in Mr Wang’s notifiable interest occurred on 27 March 2023. It appears that the Notice should have been lodged with ASX by 3 April 2023. Consequently, JAT may have breached Listing Rules 3.19A and/or 3.19B.

Request for Information

ASX Customer Service Centre 131 279 | asx.com.au

ASX Limited [[Listings]]

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Under Listing Rule 18.7, we ask that you answer each of the following questions having regard to Listing Rules 3.19A and 3.19B and Guidance Note 22: Director Disclosure of Interests and Transactions in Securities - Obligations of Listed Entities .

1. Please explain why the Appendix 3Y was lodged late.

2. What arrangements does JAT have in place under Listing Rule 3.19B with its directors to ensure that it is able to meet its disclosure obligations under Listing Rule 3.19A?

3. If the current arrangements are inadequate or not being enforced, what additional steps does JAT intend to take to ensure compliance with Listing Rule 3.19B?

When and where to send your response

This request is made under Listing Rule 18.7. Your response is required as soon as reasonably possible and, in any event, by no later than 3:00 PMAEDT Wednesday, 12 April 2023 . You should note that if the information requested by this letter is information required to be given to ASX under Listing Rule 3.1 and it does not fall within the exceptions mentioned in Listing Rule 3.1A, JAT’s obligation is to disclose the information ‘immediately’. This may require the information to be disclosed before the deadline set out in the previous paragraph and may require JAT to request a trading halt immediately.

Your response should be sent to me by e-mail at ListingsComplianceSydney@asx.com.au . It should not be sent directly to the ASX Market Announcements Office. This is to allow me to review your response to confirm that it is in a form appropriate for release to the market, before it is published on the ASX Market Announcements Platform.

Trading halt

If you are unable to respond to this letter by the time specified above, you should discuss with us whether it is appropriate to request a trading halt in JAT’s securities under Listing Rule 17.1. If you wish a trading halt, you must tell us:

• the reasons for the trading halt;

• how long you want the trading halt to last;

• the event you expect to happen that will end the trading halt;

• that you are not aware of any reason why the trading halt should not be granted; and

• any other information necessary to inform the market about the trading halt, or that we ask for.

We require the request for a trading halt to be in writing. The trading halt cannot extend past the commencement of normal trading on the second day after the day on which it is granted. You can find further information about trading halts in Guidance Note 16 Trading Halts & Voluntary Suspensions .

Suspension

If you are unable to respond to this letter by the time specified above, ASX will likely suspend trading in JAT’s securities under Listing Rule 17.3.

Listing Rules 3.1 and 3.1A

In responding to this letter, you should have regard to JAT’s obligations under Listing Rules 3.1 and 3.1A and also to Guidance Note 8 Continuous Disclosure : Listing Rules 3.1 – 3.1B. It should be noted that JAT’s obligation

2/3 ASX Customer Service Centre 131 279 | asx.com.au

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to disclose information under Listing Rule 3.1 is not confined to, nor is it necessarily satisfied by, answering the questions set out in this letter.

Release of correspondence between ASX and entity

We reserve the right to release a copy of this letter, your reply and any other related correspondence between us to the market under Listing Rule 18.7A.

Questions

If you have any questions in relation to the above, please do not hesitate to contact me.

Yours sincerely

Salvador Caldwell

Adviser Listings Compliance

3/3 ASX Customer Service Centre 131 279 | asx.com.au