SIMS LIMITED — Major Shareholding Notification 2020

Dec 8, 2020

Form 604

Corporations Act 2001 Section 671B

Notice of change of interests of substantial holder

To Company Name/Scheme	Sims Limited
ACN/ARSN/ABN	114 838 630
1. Details of substantial holder (1)
Name	Allan Gray Australia Pty Ltd (Allan Gray Australia) and its related bodies corporate as set out in Table 1 of AnnexureA (together the Group), as investment manager for the funds or investment mandates listed at Table 2 of Annexure A
ACN/ARSN (if applicable)	112 316 168 (ACN of Allan Gray Australia)
There was a change in the interests of thesubstantial holder on	7 December 2020
The previous notice was given to the company on	13 March 2020
The previous notice was dated	13 March 2020

2. Previous and present 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 when last required, and when now required, to give a substantial holding notice to the company or scheme, are as follows:

	Previous notice		Present notice
Class of securities (4)	Person's votes	Voting power (5)	Person's votes	Voting power (5)
Ordinary shares	37,794,755	18.67 %	35,537,972	17.66 %

3. Changes in relevant interests

Particulars of each change in, or change in the nature of, a relevant interest of the substantial holder or an associate in voting securities of the company or scheme, since the substantial holder was last required to give a substantial holding notice to the company or scheme are as follows:

Date of change	Person whose relevantinterest changed	Nature ofchange (6)	Considerationgiven in relationto change (7)	Class and number ofsecurities affected	Person's votesaffected
See Annexure A, Tables 2and 3

4. Present relevant interests

Particulars of each relevant interest of the substantial holder in voting securities after the change are as follows:

Holder of relevant interest	Registered holder of	Person entitled to be	Nature of relevant	Class and number	Person's
	securities	registered as holder (8)	interest (6)	of securities	votes
See Annexure A, Tables 2 and 4

5. Changes in association

The persons who have become associates (2) of, ceased to be associates of, or have changed the nature of their association (9) with, the substantial holder in relation to voting interests in the company or scheme are as follows:

Name and ACN/ARSN (if applicable)	Nature of association
See Annexure A, Tables 1 and 2

6. Addresses

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

Name	Address
The Group	C/- Allan Gray Australia, Level 2 Challis House, 4 Martin Place Sydney , NSW 2000

Signature

print name	Elizabeth Lee	Company Secretary
sign here		Date 9 December 2020

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 specifically named group if the membership of each group, with the names and addresses of members is clearly set out in paragraph 6 of the form.
• (2) See the definition of "associate" in section 9 of the Corporations Act 2001.
• (3) See the definition of "relevant interest" in sections 608 and 671B(7) of the Corporations Act 2001.
• (4) The voting shares of a company constitute one class unless divided into separate classes.
• (5) The person's votes divided by the total votes in the body corporate or scheme multiplied by 100.
• (6) Include details of:
  • (a) any relevant agreement or other circumstances because of which the change in relevant interest occurred. 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
  • (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.

• (7) 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.
• (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) Give details, if appropriate, of the present association and any change in that association since the last substantial holding notice.

Sims Limited THIS IS ANNEXURE A OF 3 PAGES REFERRED TO IN THE ABOVE FORM 604

Print name	Elizabeth Lee	Company Secretary
Sign here		Date 9 December 2020

Table 1 – Related bodies corporate

The following entities are associates of Allan Gray Australia Pty Ltd (AGA) and each other by virtue of being related bodies corporate.
Orbis Allan Gray Limited	Orbis Mansfield Street Properties Ltd
Orbis Holdings Limited	Orbis Investment Management (BVI) Limited (OIMLBVI)
Orbis Investment Management Limited (OIML)	Orbis Investment Advisory Pty Limited
Orbis Asset Management Limited (OAML)	Allan Gray (Holdings) Pty Ltd
Orbis Administration Limited	Orbis Investment Management (Hong Kong) Limited
Orbis Investment Research Limited	Orbis Client Services (Canada) Limited
Orbis Investment Management (MIS) Limited	Orbis Holdings (UK) Limited
Triple Blue Holdings Limited	Orbis Investment Management (Europe) LLP
Pictet Overseas Trust Corporation and Pictet Trustee Company SA	Orbis Investment Management (Luxembourg) S.A
Allan & Gill Gray Foundation (Guernsey)	EmCap Limited (Guernsey) (EMCAP)

Table 2 - Funds

An entity within the Group acts as investment manager for some or all of the assets in the following funds.

No	Fund name	Manager	Code	Registered holder	Persons entitled to be registeredholder
1.	Allan Gray Australia Equity Fund	AGA	SMEF	Citibank N.A., Sydney Branchas SMEF's custodian	Equity Trustees Limited as SMEF'sresponsible entity
2.	Allan Gray Australia BalancedFund	AGA	SMBF	Citibank N.A., Hong KongBranch as SMBF's custodian	Equity Trustees Limited as SMBF'sresponsible entity
3.	Allan Gray Australia Stable Fund	AGA	SMSF	Citibank N.A., Sydney Branchas SMSF's custodian	Equity Trustees Limited as SMSF'sresponsible entity
4.	AMP Capital Specialist AustralianShare Fund	AGA	SMAP	BNP Paribas Fund ServicesAustralasia Pty Ltd as SMAP'scustodian	AMP Capital Funds ManagementLimited as SMAP's responsibleentity
5.	Morningstar Australian SharesHigh Alpha Fund	AGA	SMIA	JP Morgan NomineesAustralia Ltd as SMIA'scustodian	Morningstar InvestmentManagement Australia LimitedSMIA's trustee
6.	Construction and Building UnionsSuperannuation Fund	AGA	SMCB	JP Morgan NomineesAustralia Ltd as SMCB'scustodian	United Super Pty Ltd as SMCB'strustee
7.	HESTA Superannuation Fund	AGA	SMHT	JP Morgan NomineesAustralia Ltd asSMHT's custodian	H.E.S.T. Australia Ltd as SMHT'strustee
8.	Hostplus Pooled SuperannuationTrust	AGA	SMHP	Citibank N.A., Sydney Branchas SMHP's custodian	Host Plus Pty ltd as SMHP'strustee
9.	Russell Australian OpportunitiesFund	AGA	SMRI	State Street Australia Ltd asSMRI's custodian	Russell Investment ManagementLtd as SMRI's responsible entity
10.	MyLifeMyMoney SuperannuationFund	AGA	SMCS	NAB Custodial Services ascustodian for SMCS	Togethr Trustees Pty Ltd asSMCS's trustee
11.	Maritime Super	AGA	SMMS	NAB Custodial Services ascustodian for SMMS	Maritime Super Pty Ltd as SMMS'strustee
12.	Non-Government SchoolsSuperannuation Fund	AGA	SMNG	State Street Australia Ltd asSMNG's custodian	Non-Government SchoolsSuperannuation Fund Pty Ltd asSMNG's trustee
13.	Non-Government SchoolsSuperannuation Fund	AGA	SMNP	State Street Australia Ltd asSMNP's custodian	Non-Government SchoolsSuperannuation Fund Pty Ltd asSMNP's trustee
14.	REST Superannuation Fund	AGA	SMRT	State Street Australia Ltd asSMRT's custodian	Retail Employees SuperannuationPty Ltd as SMRT's trustee
15.	Government EmployeesSuperannuation Board	AGA	SMGB	Northern Trust Corporation asSMGB's custodian	Government EmployeesSuperannuation Board

No	Fund name	Manager	Code	Registered holder	Persons entitled to be registeredholder
16.	Statewide Superannuation Trust	AGA	SMSW	NAB Custodial Services ascustodian for SMSW	Statewide Superannuation Pty Ltdas SMSW's trustee
17.	Legal Super	AGA	SMLS	BNP Paribas Fund ServicesAustralasia Pty Ltd as SMLS'scustodian	Legal Super Pty Ltd as trustee oflegalsuper
18.	Warakirri Endeavour Fund	AGA	SMWD	RBC Investor Services Trustas SMWK's custodian	Warakirri Asset Management PtyLtd SMWK's trustee
19.	Orbis Global Equity Fund(Australia Registered)	OIML	GAPL	Citibank N.A., Hong KongBranch, as GAPL's custodian	Equity Trustees Limited as GAPL'sresponsible entity
20.	Orbis Emerging Markets EquityFund (Australia Registered)	OIML	EMAF	Citibank N.A., Hong KongBranch, as EMAF's custodian	Equity Trustees Limited as EMAF'sresponsible entity
21.	Orbis Global Equity LE Fund(Australia Registered)	AGA	GALE	Citibank N.A., Hong KongBranch, as GALE's custodian	Equity Trustees Limited as GALE'sresponsible entity
22.	Orbis Global Equity Fund Limited	OIML	OGEF	Citigroup Fund ServicesCanada, Inc (Citi Canada) asOGEF's custodian	OGEF
23.	Orbis Optimal SA Fund Limited	OIML	OSAP	Citi Canada as OSAP'scustodian	OSAP
24.	Institutional Global Equity Fund	OIML	IGEF	Citi Canada as IGEF'scustodian	IGEF
25.	Orbis Optimal LP	OIML	OOLP	Citi Canada as OOLP'scustodian	OOLP
26.	Orbis International Equity LP	OIML	IELP	Citi Canada as IELP'scustodian	IELP
27.	Orbis Institutional Global EquityLP	OIML	OGLP	Citi Canada as OGLP'scustodian	OGLP
28.	Orbis Institutional InternationalEquity LP	OIML	ONLP	Citi Canada as ONLP'scustodian	ONLP
29.	Orbis Institutional U.S. Equity LP	OIML	USLP	Citi Canada as USLP'scustodian	USLP
30.	Orbis Institutional EmergingMarkets Equity LP	OIML	EMLP	Citi Canada as EMLP'scustodian	EMLP
31.	Orbis SICAV – Global EquityFund	OIML	SGPL	Citibank International plc(Luxembourg Branch) (CitiLux) as SGPL's custodian	SGPL
32.	Orbis SICAV – EmergingMarkets Fund	OIML	XJPL	Citi Lux as XJPL's custodian	XJPL
33.	Orbis SICAV – Global BalancedFund	OIML	GBSA	Citi Lux as GBSA's custodian	GBSA
34.	Orbis SICAV – InternationalEquity	OIML	SNPL	Citi Lux as SNPL's custodian	SNPL
35.	Orbis OEIC Global Equity Fund	OIML	UKGE	Citi Lux as UKGE's custodian	UKGE
36.	Orbis Institutional Global Equity(OFO)	OIML	OGEO	Citi Canada as OGEO'scustodian	OGEO
37.	OEIC Global Cautious Fund	OIML	OCS4	Citi Lux as OCS4's custodian	OCS4
38.	Orbis SICAV Global CautiousFund	OIML	OCSU	Citi Lux as OCSU's custodian	OCSU

Table 3 – Change in relevant interest

Ordinary shares
Trade Date	Reference Code	Action	No of security	Consideration	Curr
23 Mar 20 to 7 Dec 20	SMAP	Buy and Sell	415,040	2,968,360	AUD
20 Mar 20 to 4 Dec 20	SMBF	Buy and Sell	10,773	24,505	AUD
16 Mar 20 to 7 Dec 20	SMCB	Buy and Sell	-414,643	-4,485,736	AUD
12 Mar 20 to 7 Dec 20	SMCS	Buy and Sell	-10,764	-1,069,020	AUD
16 Mar 20 to 7 Dec 20	SMEF	Buy and Sell	-165,187	-3,730,893	AUD
16 Mar 20 to 7 Dec 20	SMGB	Buy and Sell	-226,612	-2,451,108	AUD

Trade Date	Reference Code	Action	No of security	Consideration	Curr
16 Mar 20 to 7 Dec 20	SMHP	Buy and Sell	-280,581	-3,037,394	AUD
16 Mar 20 to 7 Dec 20	SMHT	Buy and Sell	-288,782	-3,227,373	AUD
23 Mar 20 to 7 Dec 20	SMIA	Buy and Sell	23,038	-46,882	AUD
12 Mar 20 to 7 Sep 20	SMLS	Buy and Sell	-805,906	-6,449,640	AUD
26 Mar 20 to 7 Dec 20	SMMS	Buy and Sell	-62,991	-570,338	AUD
16 Mar 20 to 7 Dec 20	SMNG	Buy and Sell	28,914	-402,919	AUD
23 Mar 20 to 7 Dec 20	SMNP	Buy and Sell	30,001	155,755	AUD
16 Mar 20 to 7 Dec 20	SMRI	Buy and Sell	93,367	321,783	AUD
16 Mar 20 to 7 Dec 20	SMRT	Buy and Sell	-457,520	-4,999,710	AUD
12 Mar 20 to 4 Dec 20	SMSF	Buy and Sell	-49,578	-940,241	AUD
12 Mar 20 to 7 Dec 20	SMSW	Buy and Sell	-14,758	-454,701	AUD
30 Mar 20	SMWD	Sell	-80,594	-471,741	AUD
	Total		-2,256,783	-28,867,292	AUD

All trades occur on market, under a dividend reinvestment plan, or pursuant to a capital raising (as applicable).

Table 4 – Present relevant interest

Reference Code	Total no of securities
SMAP	1,069,217
SMBF	201,275
SMCB	4,332,242
SMCS	2,139,412
SMEF	9,682,470
SMGB	2,396,936
SMHP	2,986,297
SMHT	3,031,841
SMIA	362,517
SMMS	654,464
SMNG	1,115,319
SMNP	278,480
SMRI	1,302,822
SMRT	4,543,438
SMSF	562,336
SMSW	878,906
Total	35,537,972