To: PFAX201

HIGHCLERE INTERNATIONAL INVESTORS

Facsimile Cover Sheet

Attention:	ASX Online
$C_{\mathbf{C}}$ :
Company:	ASX Online
Fax number:	$+61297780999$
No. of pages:	5 (including cover page)
Date:	Wednesday, 12 March 2014
Subject:	Notice of Initial Substantial Holder

Please find attached Form 603, Notice of Initial Substantial Holder, in regards to the necessary disclosure for our holding in Reckon Limited exceeding the 5% threshold.

We will also be lodging online once given access. Any questions, please contact myself at [email protected]

Kind regards,

Emma Tapp

Highclerc International Investors

2 MANCHESTER SQUARE, LONDON WIUSPA, UK TEL: +44 (0) 20.7258 9830 PAX: +44 (0) 20.7258 9831 Company Registration No. OC355922. Aithorised and Regulated by the Financial Conduct Authority,

To: PFAX201

P.245

603 page 1/2 15 July 2001

Form 603

Corporations Act 2001 Section 671B

Notice of initial substantial holder

	To Company Name/Scheme

ACN/ARSN

N/4

RECKON LTD

003 348 730

Details of substantial holder (1)

化水气体医食品医高尔兰氏综合征

ACN/ARSN (if applicable)

HIGHCLERE INTERNATIONAL INVESTORS LLP

The holder became a substantial holder on

10/03/2014

Details of voting power

The total number of votes attached to all the voting shares in the company or voting interests in the soberne that the substantial incider or an associate (2) had arelevant interest (3) in on the date the substantial hold

Class of securities (4)	Number of securities	Person's votes (5)	Voting power (6)
ORDINARY	6,668,282	6,668,282	5.25%

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
HIGHCLERE INTERNATIONAL	JINVESTMENT MANAGEMENT	6,668,282 - ORDINARY
INVESTORS SMALLER COMPANIES
FUND

4. Details of present registered holders

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

Holder of relevantinterestHIGHCLERE INTERNATIONALINVESTORS SMALLERCOMPANIES FUND	Registered holder ofsecuritiesNORTHERN TRUST BANK	Person entitled to beregistered as holder (8)HSBC CUSTODY NOMINEES(AUSTRALIA) LIMITED	Class and numberof securities$6,668,282 -$ORDINARY

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

Holder of relevantinterest	Date of acquisition	Consideration (9)		Class and number
SEE ANNEX A		Cash	Non-cash	of securities

603 page 2/2 15 July 2001

6. Associates

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

Name and ACN/ARSN (if applicable)	Nature of association
NORTHERN TRUST BANK	CUSTODIAN BANK
HSBC CUSTODY NOMINEES	SUB-AGENT OF CUSTODIAN BANK
(AUSTRALIA) LIMITED

7. Addresses

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

______________________________________	_____
Name	÷.
The Company of Company's Law
.	Address
FEE ANNEX B--- --	-------

Signature
	print name	$-2$	capacity PARTNER
	sign here	FCILMOUR	1031204date 11

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 spocifically 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.
See the definition of "relevant Interest" in sections 608 and 671B(7) of the Corporations Act. 2001. $(3)$
$(4)$ 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 6718(4) applies, a copy of any document setting out $(a)$ 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 cortifying this contract, scheme or arrangement; and
- $(b)$ any qualification of the power of a person to exercise, control the exercise of, or influence the exercise of, the voting 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 Act 2001.

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". $(8)$
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 $(9)$ 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.

$\mathbf{f}$

ANNEX A