TOWER LIMITED — Major Shareholding Notification 2020

Apr 1, 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: 30/03/2020 Date this disclosure made: 31/03/2020 Date last disclosure made: 19/02/2020

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

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

For last disclosure,—

(a) total number held in class: 22,024,305 (b) total in class: 421,647,258

• (c) total percentage held in class: 5.22%

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: 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

For last disclosure,—

• ((a) total number held in class: 13,774,341 (b) total in class: 421,647,258

• (c) total percentage held in class: 3.27%

DEVON
CITI forprivate client	698,557
BNP forprivate client	1,761,000
BNP forprivate client	3,190,248
BNP forprivate client	339,822
MMC forprivate client	1,407,152
JPM forprivate client	997,073
Northern Trust forprivate client	4,434,500
JPM forprivate client	628,067
Public Trust forprivate client	228,139
BNP for wholesale clients	89,783

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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: 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 last disclosure,—

• (a) total number held in class:

8,249,964

• (b) total in class: 421,647,258

• (c) total percentage held in class:

• 1.96%

CLARITY
BNP for retails clients	3,936,250
BNP for retails clients	153,714
BNP for retails clients	4,160,000

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 30/11/2019 and 30/03/2020.

Transaction Type	Volume	Consideration Paid	Consideration Received
Sales	0		$0
Purchases	11,704,750	$7,912,480.81

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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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