Tower Limited — Major Shareholding Notification 2022

Jun 29, 2022

Disclosure of movement of 1% or more in substantial holding or change in nature of relevant interest, or both

Sections 277 and 278, Financial Markets Conduct Act 2013

This form must be completed in accordance with the instructions at the end of the form.

To ASX, NZX

and

To Tower Limited

Relevant event being disclosed:

Date of relevant event: 28/06/2022 Date this disclosure made: 29/06/2022

Date last disclosure made: 19/04/2021

Substantial product holder(s) giving disclosure

Full name(s): Investment Services Group Limited (formerly Devon Funds Group Limited)

Summary of substantial holding

Class of quoted voting products: Ordinary Shares

Summary for Investment Services Group Limited

For this disclosure,—

(a) total number held in class: 20,589,363 (b) total in class: 379,483,987 (c) total percentage held in class: 5.43% For last disclosure, — (a) total number held in class: 27,379,134 (b) total in class: 421,647,258 (c) total percentage held in class: 6.49%

Details of relevant interests

Devon Funds Management Limited and Clarity Funds Management Limited are subsidiaries of Investment Services Group Limited.

Details for Devon Funds Management Limited

Nature of relevant interest(s): Related party of Investment Services Group Limited

For this disclosure,—

• (a) total number held in class: 11,020,242

• (b) total in class: 379,483,987

• (c) total percentage held in class: 2.90%

DEVON	Units
BNP forprivate client	4,117,814
BNP forprivate client	272,103
JPM forprivate client	2,281,922
Northern forprivate client	2,945,290
JPM forprivate client	1,112,237
BNP for wholesale clients	290,876

For last disclosure,—

Summary for Devon Funds Management Limited

• (a) total number held in class: 17,475,787 (b) total in class: 421,647,258

• (c) total percentage held in class: 4.14%

DEVON	Units
CITI forprivate client	839,212
BNP forprivate client	2,107,848
BNP forprivate client	3,770,913
BNP forprivate client	291,627
MMC forprivate client	1,602,748
JPM forprivate client	1,316,860
Northern forprivate client	5,364,730
JPM forprivate client	763,618
Public Trust forprivate client	964,562
BNP for wholesale clients	453,669

Details for Clarity Funds Management Limited

Nature of relevant interest(s): Related party of Investment Services Group Limited.

For this disclosure: -

• (a) total number held in class: 9,569,121

(b) total in class: 379,483,987

• (c) total percentage held in class: 2.52%

CLARITY
BNP for retails clients	4,823,200
BNP for retails clients	339,020
BNP for retails clients	4,406,901

For last disclosure, —

• (a) total number held in class: 9,903,347

• (b) total in class: 421,647,258

• (c) total percentage held in class: 2.35%

CLARITY
BNP for retails clients	5,880,163
BNP for retails clients	3,699,913
BNP for retails clients	323,271

For a derivative relevant interest, also—

• (a) type of derivative: N/A

• (b) details of derivative:

N/A

• (c) parties to the derivative: N/A

• (d) if the substantial product holder is not a party to the derivative, the nature of the relevant interest in the derivative: N/A

Details of transactions and events giving rise to substantial holding

Details of the transactions or other events requiring disclosure: Transactions between 19/04/2021 to 28/06/2022

Transaction Type	Volume	Consideration Paid	Consideration Received
Sales	10,409,693		$7,351,382
Purchases	9,970,326	$7,012,677

Additional information

Address(es) of substantial product holder(s): Investment Services Group Limited, Level 17, 188 Quay Street, Auckland 1010

Contact details: Suki Chow | P: 09 925 3989 | E: schow@devonfunds.co.nz

Name of any other person believed to have given, or believed to be required to give, a disclosure under the Financial Markets Conduct Act 2013 in relation to the financial products to which this disclosure relates: Devon Funds Management Limited

Certification

I, Suki Chow , certify that, to the best of my knowledge and belief, the information contained in this disclosure is correct and that I am duly authorised to make this disclosure by all persons for whom it is made.