TOWER LIMITED — Major Shareholding Notification 2020

Oct 21, 2020

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

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

To NZX, ASX

and

To Tower Limited

Relevant event being disclosed:

Date of relevant event: 20/10/2020 Date this disclosure made: 21/10/2020 Date last disclosure made: 31/03/2020

Substantial product holder(s) giving disclosure Full name(s): Investment Services 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: 31,974,122 (b) total in class: 421,647,258

• (c) total percentage held in class: 7.58%

For last disclosure,—

(a) total number held in class: 26,916,217 (b) total in class: 421,647,258

• (c) total percentage held in class: 6.38%

Details of relevant interests

Devon Funds Management Limited is a subsidiary of Investment Services Group Limited

Details for Devon Funds Management Limited

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

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For this disclosure,—

• (a) total number held in class: 20,906,050

• (b) total in class: 421,647,258

• (c) total percentage held in class: 4.96%

CUSTODIAN	UNITS
CITI forprivate client	1,068,205
BNP forprivate client	2,709,912
BNP forprivate client	4,088,534
Northern forprivate client	351,924
BNP forprivate client	2,133,147
MMC forprivate client	1,593,346
JPM forprivate client	6,171,846
JPM forprivate client	975,262
Public Trust forprivate client	1,250,697
BNP for wholesale clients	563,177

For last disclosure,—

((a) total number held in class: 18,106,253

• (b) total in class: 421,647,258

• (c) total percentage held in class: 4.29%

CUSTODIAN	UNITS
CITI forprivate client	894,376
BNP forprivate client	2,245,210
BNP forprivate client	4,076,493
Northern forprivate client	349,486
BNP forprivate client	1,790,813
MMC forprivate client	1,311,411
JPM forprivate client	5,764,201
JPM forprivate client	917,259
Public Trust forprivate client	542,311
BNP for wholesale clients	214,693

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Details for Clarity Funds Management Limited

Nature of relevant interest(s): Investment manager of various funds

For this disclosure,—

• (a) total number held in class: 11,068,072

• (b) total in class: 421,647,258

• (c) total percentage held in class:

• 2.62%

CLARITY BNP for retails clients BNP for retails clients BNP for retails clients
	6,626,186
	4,015,768
	426,118

For last disclosure,—

• (a) total number held in class:

8,809,964

• (b) total in class: 421,647,258

• (c) total percentage held in class:

• 2.09%

CLARITY
BNP for retails clients	3,936,250
BNP for retails clients	213,714
BNP for retails clients	4,660,000

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 20/06/2020 and 20/10/2020.

Transaction Type	Volume	Consideration Paid	Consideration Received
Sales	866,359		$502,488.22

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Purchases 6,047,754

$3,545,913.51

Additional information

Address(es) of substantial product holder(s): Investment Services Group Management, Level 10, 2 Commerce Street, Auckland 1010

Contact details: Snigdha Arun | P: +64 9 925 3986 | E: sarun@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 Ltd and Clarity Funds Management Ltd

Certification

I, Snigdha Arun, 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.

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