SIMS LIMITED — Major Shareholding Notification 2025

Jan 12, 2025

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 LIMITED

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 09 / 01 / 2025

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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----- Start of picture text ----- Class of securities (4) Number of securities Person's votes (5) Voting power (6)Fully paid ordinary9,716,679 9,716,679 5.029%shares----- End of picture text -----

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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----- Start of picture text ----- Holder of relevant interest Nature of relevant interest (7) Class and number of securitiesPower to exercise voting rightsAustralian Retirement Trustpursuant to position held as Fully paid ordinaryPty LTD ATF Australiantrustee of a superannuation shares 9,716,679Retirement Trustfund.----- End of picture text -----

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 relevantinterest	Registered holder ofsecurities	Person entitled to beregistered as holder (8)	Class and number of securities
AustralianRetirement Trust PtyLTD ATF AustralianRetirement Trust	HSBC CustodyNominees(Australia)Limited		Fully paid ordinaryshares 9,716,679

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 relevantinterest	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 Kristy Huxtable capacity Authorised Signatory sign here date 13 / 01 / 2025

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.

Page 1 of 1

Annexure A

Australian Retirement Trust Pty Ltd ATF Australian Retirement Trust ACN 010 720 840

This is Annexure A of 1 page referred to in Form 603, Notice of initial substantial holder

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----- Start of picture text ----- Kristy HuxtableCompany Secretary Date: 13/01/2025Consideration Consideration Number ofHolder of Relevant Interest Purchase/Sale Trade Date(Cash) (Non-Cash) SecuritiesAustralian Retirement Trust Pty Ltd ATF Australian Retirement Trust BUY 13/09/2024 57,747.90 5,397Australian Retirement Trust Pty Ltd ATF Australian Retirement Trust SELL 23/09/2024 583,794.60 49,254Australian Retirement Trust Pty Ltd ATF Australian Retirement Trust BUY 10/10/2024 254,965.62 20,013Australian Retirement Trust Pty Ltd ATF Australian Retirement Trust BUY 14/10/2024 120,156.72 9,358Australian Retirement Trust Pty Ltd ATF Australian Retirement Trust BUY 15/10/2024 209,770.92 16,414Australian Retirement Trust Pty Ltd ATF Australian Retirement Trust SELL 4/11/2024 45,697.14 3,600Australian Retirement Trust Pty Ltd ATF Australian Retirement Trust BUY 11/11/2024 53,510.10 3,975Australian Retirement Trust Pty Ltd ATF Australian Retirement Trust SELL 14/11/2024 34,084,104.96 2,679,568Australian Retirement Trust Pty Ltd ATF Australian Retirement Trust BUY 14/11/2024 34,084,104.96 2,679,568Australian Retirement Trust Pty Ltd ATF Australian Retirement Trust SELL 18/11/2024 49,965.75 3,975Australian Retirement Trust Pty Ltd ATF Australian Retirement Trust BUY 27/11/2024 274,201.69 21,642Australian Retirement Trust Pty Ltd ATF Australian Retirement Trust BUY 29/11/2024 2,532.72 196Australian Retirement Trust Pty Ltd ATF Australian Retirement Trust BUY 3/12/2024 51.73 4Australian Retirement Trust Pty Ltd ATF Australian Retirement Trust BUY 9/12/2024 4,939.33 384Australian Retirement Trust Pty Ltd ATF Australian Retirement Trust BUY 10/12/2024 160,726.37 12,453Australian Retirement Trust Pty Ltd ATF Australian Retirement Trust BUY 11/12/2024 109,134.61 8,524Australian Retirement Trust Pty Ltd ATF Australian Retirement Trust BUY 13/12/2024 129,296.42 9,978Australian Retirement Trust Pty Ltd ATF Australian Retirement Trust BUY 16/12/2024 66,708.76 5,163Australian Retirement Trust Pty Ltd ATF Australian Retirement Trust BUY 17/12/2024 59,376.28 4,702Australian Retirement Trust Pty Ltd ATF Australian Retirement Trust BUY 18/12/2024 195,644.98 15,711Australian Retirement Trust Pty Ltd ATF Australian Retirement Trust BUY 18/12/2024 30,805.95 2,470Australian Retirement Trust Pty Ltd ATF Australian Retirement Trust SELL 19/12/2024 815,674.20 65,516Australian Retirement Trust Pty Ltd ATF Australian Retirement Trust SELL 23/12/2024 191,663.37 15,983Australian Retirement Trust Pty Ltd ATF Australian Retirement Trust SELL 23/12/2024 504,774.17 42,037Australian Retirement Trust Pty Ltd ATF Australian Retirement Trust BUY 8/01/2025 389,890.56 31,360Australian Retirement Trust Pty Ltd ATF Australian Retirement Trust BUY 9/01/2025 749,119.13 60,000----- End of picture text -----