TITOMIC LIMITED — Director's Dealing 2023

Aug 13, 2023

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11 August 2023

Ms Ash Abdul Aziz Adviser, Listings Compliance ASX

By email: ListingsComplianceMelbourne@asx.com.au

Dear Ms Aziz

Titomic Limited (‘TTT’): Appendix 3Y- Change of Director’s Interest Notice Query

I refer to your letter dated 8 August regarding the above matter. In answer to your Request for Information, please see replies below:

1 Please explain why the Appendix 3Y was lodged late?

The late lodgement of the Appendix 3Ys was a result of an administrative oversight.

The change in Directors’ interests resulted from participation by Directors in the recent Rights Issue.

2 What arrangements does TTT have in place under Listing Rule 3.19B with its directors to ensure that it is able to meet its disclosure obligations under Listing Rule 3.19A?

Under the Company’s Securities Trading Policy, the Company has arrangements in place

whereby Directors are required to provide timely, ongoing disclosure to the Company of all changes in interests in the Company’s Securities to enable the Company to give ASX a completed Appendix 3Y within the required timeframe, and thereby meet its disclosure obligation under Listing Rule 3.19A.

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Titomic Limited Ground floor, 365 Ferntree Gully Road Mount Waverley, Victoria 3149, Australia

info@titomic.com | titomic.com

1

ABN 77 602 793 644

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3 If the current arrangements are inadequate or not being enforced, what additional steps does TTT intend to take to ensure compliance with Listing Rule 3.19B?

TTT considers the current arrangements to be adequate to ensure timely compliance with Listing Rule 3.19B. The failure to do so on this occasion is regrettable. TTT has reminded Directors of their disclosure obligations.

TTT will also ask its registry, Computershare, to advise the Company Secretary in a timely manner of any changes in Directors’ holdings which comes to its attention.

I trust the above addresses your Requests, but please let me know if I can be of any further assistance.

Kind regards

Chris Healy

Company Secretary

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Titomic Limited Ground floor, 365 Ferntree Gully Road

Mount Waverley, Victoria 3149, Australia

info@titomic.com | titomic.com

2

ABN 77 602 793 644

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8 August 2023 Reference: 77757

Mr Chris Healy Company Secretary Titomic Limited

By email: chris.healy@titomic.com

Dear Mr Healy

Titomic Limited (‘TTT’): Appendix 3Y – Change of Director’s Interest Notice Query

ASX refers to the following:

1. TTT’s Appendix 3Y lodged on the ASX Market Announcements Platform (‘MAP’) on 8 August 2023 for Mr Humphrey Nolan;

2. TTT’s Appendix 3Y lodged on the ASX Market Announcements Platform MAP on 8 August 2023 for Mr Herbert Koeck;

3. TTT’s Appendix 3Y lodged on the ASX Market Announcements Platform MAP on 8 August 2023 for Mr Dag Stromme (together, the ‘Appendix 3Y Notices’);

4. Listing Rule 3.19A which requires an entity to tell ASX the following:

5. 3.19A.1 ‘The notifiable interests of a director of the entity (or in the case of a trust, a director of the responsible entity of the trust) at the following times.

   • On the date that the entity is admitted to the official list.

   • On the date that a director is appointed.

The entity must complete Appendix 3X and give it to ASX no more than 5 business days after the entity’s admission or a director’s appointment.

• 3.19A.2 A change to a notifiable interest of a director of the entity (or in the case of a trust, a director of the responsible entity of the trust) including whether the change occurred during a closed period where prior written clearance was required and, if so, whether prior written clearance was provided. The entity must complete Appendix 3Y and give it to ASX no more than 5 business days after the change occurs.

3.19A.3 The notifiable interests of a director of the entity (or in the case of a trust, a director of the responsible entity of the trust) at the date that the director ceases to be a director. The entity must complete Appendix 3Z and give it to ASX no more than 5 business days after the director ceases to be a director.’

1. Listing rule 3.19B which states that:

‘An entity must make such arrangements as are necessary with a director of the entity (or in the case of a trust, a director of the responsible entity of the trust) to ensure that the director discloses to the entity all the information required by the entity to give ASX completed Appendices 3X, 3Y and 3Z within the time period allowed by listing rule 3.19.A. The entity must enforce the arrangements with the director.’

ASX Customer Service Centre 131 279 | asx.com.au

ASX Limited [[Listings]]

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The Appendix 3Y Notices indicate that a change in each Directors’ notifiable interest occurred on 24 July 2023. It appears that the Notice should have been lodged with ASX by 31 July 2023. Consequently, TTT may have breached Listing Rules 3.19A and/or 3.19B.

Request for Information

Under Listing Rule 18.7, we ask that you answer each of the following questions having regard to Listing Rules 3.19A and 3.19B and Guidance Note 22: Director Disclosure of Interests and Transactions in Securities - Obligations of Listed Entities .

1. Please explain why the Appendix 3Y was lodged late.

2. What arrangements does TTT have in place under Listing Rule 3.19B with its directors to ensure that it is able to meet its disclosure obligations under Listing Rule 3.19A?

3. If the current arrangements are inadequate or not being enforced, what additional steps does TTT intend to take to ensure compliance with Listing Rule 3.19B?

When and where to send your response

This request is made under Listing Rule 18.7. Your response is required as soon as reasonably possible and, in any event, by no later than 9.30 AM AEST Monday, 14 August 2023 . You should note that if the information requested by this letter is information required to be given to ASX under Listing Rule 3.1 and it does not fall within the exceptions mentioned in Listing Rule 3.1A, TTT’s obligation is to disclose the information ‘immediately’. This may require the information to be disclosed before the deadline set out in the previous paragraph and may require TTT to request a trading halt immediately.

Your response should be sent to me by e-mail at ListingsComplianceMelbourne@asx.com.au . It should not be sent directly to the ASX Market Announcements Office. This is to allow me to review your response to confirm that it is in a form appropriate for release to the market, before it is published on the ASX Market Announcements Platform.

Trading halt

If you are unable to respond to this letter by the time specified above, you should discuss with us whether it is appropriate to request a trading halt in TTT’s securities under Listing Rule 17.1. If you wish a trading halt, you must tell us:

• the reasons for the trading halt;

• how long you want the trading halt to last;

• the event you expect to happen that will end the trading halt;

• that you are not aware of any reason why the trading halt should not be granted; and

• any other information necessary to inform the market about the trading halt, or that we ask for.

We require the request for a trading halt to be in writing. The trading halt cannot extend past the commencement of normal trading on the second day after the day on which it is granted. You can find further information about trading halts in Guidance Note 16 Trading Halts & Voluntary Suspensions .

Suspension

If you are unable to respond to this letter by the time specified above, ASX will likely suspend trading in TTT’s securities under Listing Rule 17.3.

2/3 ASX Customer Service Centre 131 279 | asx.com.au

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Listing Rules 3.1 and 3.1A

In responding to this letter, you should have regard to TTT’s obligations under Listing Rules 3.1 and 3.1A and also to Guidance Note 8 Continuous Disclosure : Listing Rules 3.1 – 3.1B. It should be noted that TTT’s obligation to disclose information under Listing Rule 3.1 is not confined to, nor is it necessarily satisfied by, answering the questions set out in this letter.

Release of correspondence between ASX and entity

ASX reserves the right to release all or any part of this letter, your reply and any other related correspondence between us to the market under Listing Rule 18.7A.

Questions

If you have any questions in relation to the above, please do not hesitate to contact me.

Kind regards

Ash Abdul Aziz

Adviser, Listings Compliance

3/3 ASX Customer Service Centre 131 279 | asx.com.au