LENDLEASE GROUP — Director's Dealing 2023

Dec 4, 2023

1 December 2023

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Mr Elvis Onyura Principal Advisor, Listings Compliance Australian Securities Exchange 20 Bridge Street, Sydney, NSW 2000

By email: ListingsComplianceSydney@asx.com.au

Dear Mr Onyura

Lendlease Group (LLC): Appendix 3Y – Change of Director’s Interest Notice Query

We refer to your letter of 29 November 2023 in relation to the late lodgement of the Appendix 3Y for Mr Anthony Peter Lombardo and respond as follows:

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

The Appendix 3Y was lodged late due to an administrative error at the time of the allocation of securities by our Reward team, as a result of leave arrangements with personnel. As soon as the oversight was identified, steps were taken promptly to arrange for the Appendix 3Y to be lodged with the ASX.

2. What arrangements does LLC 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?

This was an isolated incident relating to leave arrangements in our Reward team. This did not relate to a failure by any Director to advise of their relevant interests.

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

The Company considers the late lodgement to be an isolated breach and that its current arrangements are adequate to ensure compliance with the ASX Listing Rules. Nevertheless, the Company has put in place additional processes in respect of its Employee Share Plan and a re-allocation of responsibilities internally to prevent oversights of this nature from reoccurring.

Yours sincerely

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Wendy Lee Company Secretary Lendlease Group

Lendlease Corporation Limited ABN 32 000 226 228; and Lendlease Responsible Entity Limited ABN 72 122 883 185 AFS Licence 308983 as responsible entity for Lendlease Trust ABN 39 944 184 773 ARSN 128 052 595 Level 14, Tower Three, International Towers Sydney, Exchange Place 300 Barangaroo Avenue, Barangaroo NSW 2000 Australia www.lendlease.com

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29 November 2023

Reference: 85663

Ms Wendy Lee Company Secretary Lendlease Group Level 14 Tower Three International Towers Sydney Exchange Place 300 Barangaroo Avenue Barangaroo NSW 2000

By email

Dear Ms Lee

Lendlease Group (‘LLC’): Appendix 3Y – Change of Director’s Interest Notice Query

ASX refers to the following:

1. LLC’s Appendix 3Y lodged on the ASX Market Announcements Platform (‘MAP’) on 28 November 2023 for Mr Anthony Peter Lombardo (the ‘Notice’);

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

3. 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.’

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

ASX Limited [[Listings]]

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The Notice indicates that a change in Mr Lombardo’s notifiable interest occurred on 24 October 2023. It appears that the Notice should have been lodged with ASX by 31 October 2023. Consequently, LLC may have breached Listing Rules 3.19A and/or 3.19B. It also appears that Mr Lombardo may have breached section 205G of the Corporations Act 2001 (Cth).

Request for Information

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 LLC 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 LLC 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 9:30 AM AEDT on Monday, 4 December 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, LLC’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 LLC 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 LLC’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 .

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

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Suspension

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

Listing Rules 3.1 and 3.1A

In responding to this letter, you should have regard to LLC’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 LLC’s obligation 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

ASX reserves the right to release all or any part 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.

Kind regards

Elvis Onyura

Principal Adviser, Listings Compliance

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

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