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TELSTRA GROUP LIMITED — Director's Dealing 2024
Jun 3, 2024
65927_rns_2024-06-03_916c74b1-7a86-4d5b-b21d-f4d4bbd43023.pdf
Director's Dealing
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4 June 2024
Office of the Company Secretary
Market Announcements Office Australian Securities Exchange 4[th] Floor, 20 Bridge Street Sydney NSW 2000
Level 41 242 Exhibition Street MELBOURNE VIC 3000 AUSTRALIA
ELECTRONIC LODGEMENT
- Telstra Group Limited (ACN 650 620 303) – ASX: TLS
Change of Director’s Interest Notice
Telstra Group Limited ( Telstra ) has recently become aware that Ms Elana Rubin holds an indirect interest in a total of 19,242 Telstra shares that were acquired on market between 10 August 2022 and 19 April 2024.
Those shares were acquired and are held through a Macquarie Separately Managed Account ( SMA ) held jointly by Ms Rubin and her partner. The SMA contains a portfolio of investments that are managed by Link Financial Services Pty Ltd ( LFS ) in accordance with a model portfolio it has established.
Ms Rubin has confirmed that:
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the relevant Telstra shares (and the other investments held in the SMA) were acquired in line with the model portfolio and at the direction of LFS;
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she had no involvement in the actual acquisitions of the relevant Telstra shares; and
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she has no involvement in the acquisition/disposal of any shares in the LFS Equity account.
The relevant Telstra shares are held by Bond Street Custodians Limited as the custodian in relation to the SMA.
Indirect and incidental trading that occurs when a director deals in shares of a managed investment scheme, listed investment company, exchange-traded fund or similar investment vehicle that is managed by a third party and that happens to hold Telstra shares as part of its portfolio is classified as an “Excluded Dealing” for the purposes of Telstra’s securities trading policy. The obligations and restrictions relating to window periods, approvals, notifications and prohibited dealings set out in the policy do not apply. However, directors are required to notify the Telstra Company Secretary before dealing in reliance on that exclusion. As Ms Rubin was not aware of the trades at the time they occurred, she was unable to comply with the requirement to notify the Telstra Company Secretary and an Appendix 3Y was not given to ASX in respect of the trades. Upon Ms Rubin becoming aware of the trades, she notified the Telstra Company Secretary, and as a result, an updated Appendix 3Y reflecting the impact of those trades is now attached.
Telstra is satisfied that the failure to notify the Telstra Company Secretary of these trades was inadvertent, that Ms Rubin had no involvement in the investment decisions and that Ms Rubin disclosed the trades promptly upon becoming aware of them.
Telstra is also satisfied that Ms Rubin has put in place arrangements to prevent a recurrence.
Release of announcement authorised by:
Sue Laver Company Secretary
Appendix 3Y Change of Director’s Interest Notice
Rule 3.19A.2
Appendix 3Y
Change of Director’s Interest Notice
Information or documents not available now must be given to ASX as soon as available. Information and documents given to ASX become ASX’s property and may be made public.
Introduced 30/09/01 Amended 01/01/11
Name of entity TELSTRA GROUP LIMITED
ABN 56 650 620 303
We (the entity) give ASX the following information under listing rule 3.19A.2 and as agent for the director for the purposes of section 205G of the Corporations Act.
| Name of Director | ELANA RUBIN |
|---|---|
| Date of last notice | 25 AUGUST 2023 |
Part 1 ‐ Change of director’s relevant interests in securities
In the case of a trust, this includes interests in the trust made available by the responsible entity of the trust
Note: In the case of a company, interests which come within paragraph (i) of the definition of “notifiable interest of a director” should be disclosed in this part.
| Direct or indirect interest | Direct and indirect interests |
|---|---|
| Nature of indirect interest (including registered holder) Note: Provide details of the circumstances giving rise to the relevant interest. |
Indirect interest in shares held by Bond Street Custodians Limited as custodian for Macquarie Separately Managed Account held by Ms Rubin and her Partner jointly. |
| Date of change | 15 August 2022 to 19 April 2024 |
| No. of securities held prior to change | Direct – 70,406 Indirect – Nil |
| Class | ORDINARY |
| Number acquired | 19,424 |
| Number disposed | Nil |
| Value/Consideration Note: If consideration is non-cash, provide details and estimated valuation |
Approximately $76,582 |
| No. of securities held after change | Direct – 70,406 Indirect–19,424 |
| Nature of change Example: on-market trade, off-market trade, exercise of options, issue of securities under dividend reinvestment plan, participation in buy-back |
On market purchase of shares |
- See chapter 19 for defined terms.
01/01/2011 Appendix 3Y Page 1
Appendix 3Y Change of Director’s Interest Notice
Part 2 – Change of director’s interests in contracts
Note: In the case of a company, interests which come within paragraph (ii) of the definition of “notifiable interest of a director” should be disclosed in this part.
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Detail of contract
Nature of interest
Name of registered holder
(if issued securities)
Date of change
No. and class of securities to which
interest related prior to change
Note: Details are only required for a contract in relation
to which the interest has changed
Interest acquired
Interest disposed
Value/Consideration
Note: If consideration is non-cash, provide details and an
estimated valuation
Interest after change
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Part 3 –[+] Closed period
Were the interests in the securities or contracts detailed Refer to the attached cover above traded during a[+] closed period where prior written letter. clearance was required? If so, was prior written clearance provided to allow the trade to proceed during this period? If prior written clearance was provided, on what date was this provided?
- See chapter 19 for defined terms.
Appendix 3Y Page 2
01/01/2011