SIMS LIMITED — Major Shareholding Notification 2024

Aug 8, 2024

603 Page 1 of 3 15 July 2001

Form 603

Corporations Act 2001

Section 671B

Notice of initial substantial holder

To Company Name/Scheme SIMS LTD

ACN/ARSN 114 838 630

1. Details of substantial holder (1)

Name Australian Retirement Trust Pty LTD ATF Australian Retirement Trust ACN/ARSN (if applicable) 010 720 840

The holder became a substantial holder on 07 / 08 / 2024

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:

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Class of securities (4) Number of securities Person's votes (5) Voting power (6)
Fully paid ordinary
9,668,105 9,668,105 5.004%
shares
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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:

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Holder of relevant interest Nature of relevant interest (7) Class and number of securities
Power to exercise voting rights
Australian Retirement Trust
pursuant to position held as Fully paid ordinary
Pty LTD ATF Australian
trustee of a superannuation shares 9,668,105
Retirement Trust
fund.
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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 relevant interest	Registered holder of securities	Person entitled to be registered as holder (8)	Class and number of securities
Australian Retirement Trust Pty LTD ATF Australian Retirement Trust	HSBC Custody Nominees (Australia)Limited		Fully paid ordinary shares 9,668,105

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)	Consideration (9)	Class and number of securities
		Cash	Non-cash
Refer to Annexure A

603 Page 2 of 3 15 July 2001

6. Associates

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

Name and ACN/ARSN (if applicable) Nature of association

7. Addresses

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

Name Address Australian Retirement Trust Pty LTD ATF 266 George Street, Brisbane City QLD 4000 Australian Retirement Trust

Signature

print name Steven Moggian Joshua King capacity Authorised Signatory sign here date 09 / 08 / 2024

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 7 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 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:

• (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

• (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.

• (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

603 Page 3 of 3 15 July 2001

relation to the acquisitions, even if they are not paid directly to the person from whom the relevant interest was acquired.

Annexure A

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Consideration Consideration Number of
Holder of Relevant Interest Purchase/Sale Trade Date
(Cash) (Non-Cash) Securities
Australian Retirement Trust Pty Ltd ATF Australian Retirement Trust BUY 8/04/2024 2,088.32 169
Australian Retirement Trust Pty Ltd ATF Australian Retirement Trust BUY 8/04/2024 381,306.28 30,798
Australian Retirement Trust Pty Ltd ATF Australian Retirement Trust SELL 9/04/2024 19,807.55 1,600
Australian Retirement Trust Pty Ltd ATF Australian Retirement Trust BUY 9/04/2024 1,480,173.94 119,202
Australian Retirement Trust Pty Ltd ATF Australian Retirement Trust BUY 10/04/2024 90,060.48 7,190
Australian Retirement Trust Pty Ltd ATF Australian Retirement Trust BUY 11/04/2024 1,655,025.48 133,077
Australian Retirement Trust Pty Ltd ATF Australian Retirement Trust BUY 12/04/2024 759,706.71 61,145
Australian Retirement Trust Pty Ltd ATF Australian Retirement Trust BUY 15/04/2024 27,014.38 2,167
Australian Retirement Trust Pty Ltd ATF Australian Retirement Trust BUY 15/04/2024 1,962,441.51 158,588
Australian Retirement Trust Pty Ltd ATF Australian Retirement Trust BUY 16/04/2024 1,824,119.25 150,000
Australian Retirement Trust Pty Ltd ATF Australian Retirement Trust BUY 17/04/2024 1,952,045.07 160,000
Australian Retirement Trust Pty Ltd ATF Australian Retirement Trust BUY 18/04/2024 1,819,699.55 150,000
Australian Retirement Trust Pty Ltd ATF Australian Retirement Trust BUY 19/04/2024 1,529,479.46 130,000
Australian Retirement Trust Pty Ltd ATF Australian Retirement Trust BUY 23/04/2024 1,345,155.55 113,000
Australian Retirement Trust Pty Ltd ATF Australian Retirement Trust BUY 24/04/2024 5,010.95 425
Australian Retirement Trust Pty Ltd ATF Australian Retirement Trust BUY 2/05/2024 1,530.75 129
Australian Retirement Trust Pty Ltd ATF Australian Retirement Trust BUY 7/05/2024 127,755.37 11,965
Australian Retirement Trust Pty Ltd ATF Australian Retirement Trust BUY 7/05/2024 771,560.70 70,000
Australian Retirement Trust Pty Ltd ATF Australian Retirement Trust BUY 7/05/2024 136,917.81 12,343
Australian Retirement Trust Pty Ltd ATF Australian Retirement Trust BUY 8/05/2024 105,916.01 9,699
Australian Retirement Trust Pty Ltd ATF Australian Retirement Trust BUY 9/05/2024 38,662.93 3,556
Australian Retirement Trust Pty Ltd ATF Australian Retirement Trust BUY 10/05/2024 31,323.69 2,911
Australian Retirement Trust Pty Ltd ATF Australian Retirement Trust BUY 13/05/2024 10,992.45 1,000
Australian Retirement Trust Pty Ltd ATF Australian Retirement Trust BUY 16/05/2024 308,182.29 28,509
Australian Retirement Trust Pty Ltd ATF Australian Retirement Trust SELL 16/05/2024 308,182.29 28,509
Australian Retirement Trust Pty Ltd ATF Australian Retirement Trust BUY 23/05/2024 1,042,274.72 92,500
Australian Retirement Trust Pty Ltd ATF Australian Retirement Trust BUY 24/05/2024 1,034,886.25 92,500
Australian Retirement Trust Pty Ltd ATF Australian Retirement Trust SELL 31/05/2024 1,150,200.10 108,534
Australian Retirement Trust Pty Ltd ATF Australian Retirement Trust BUY 5/06/2024 749,941.66 70,351
Australian Retirement Trust Pty Ltd ATF Australian Retirement Trust BUY 5/06/2024 344,447.66 32,290
Australian Retirement Trust Pty Ltd ATF Australian Retirement Trust BUY 6/06/2024 638,016.63 59,710
Australian Retirement Trust Pty Ltd ATF Australian Retirement Trust BUY 11/06/2024 728,697.06 69,202
Australian Retirement Trust Pty Ltd ATF Australian Retirement Trust BUY 13/06/2024 738,103.59 70,497
Australian Retirement Trust Pty Ltd ATF Australian Retirement Trust BUY 24/06/2024 13,749,364.45 1,333,595
Australian Retirement Trust Pty Ltd ATF Australian Retirement Trust SELL 24/06/2024 13,749,364.45 1,333,595
Australian Retirement Trust Pty Ltd ATF Australian Retirement Trust BUY 21/06/2024 6,186.03 600
Australian Retirement Trust Pty Ltd ATF Australian Retirement Trust BUY 24/06/2024 1,511,628.28 150,000
Australian Retirement Trust Pty Ltd ATF Australian Retirement Trust BUY 10/07/2024 20,712.45 2,000
Australian Retirement Trust Pty Ltd ATF Australian Retirement Trust BUY 24/07/2024 2,501.45 248
Australian Retirement Trust Pty Ltd ATF Australian Retirement Trust SELL 1/08/2024 465,948.78 45,771
Australian Retirement Trust Pty Ltd ATF Australian Retirement Trust BUY 1/08/2024 465,948.78 45,771
Australian Retirement Trust Pty Ltd ATF Australian Retirement Trust BUY 7/08/2024 1,005,086.34 100,000
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