XREF LIMITED — Regulatory Filings 2026

May 13, 2026

XREF

14 May 2026

Via email: listingscompliancesydney@asx.com.au

Dear ASX Compliance

Xref Limited ('XF1'): Appendix 3Z – Final Director’s Interest Notice Query

We refer to ASX’s letter dated 13 May 2026 regarding the late lodgement of the Appendix 3Z Final Director’s Interest Notice for Mr Tom Stianos and respond as follows:

1. The Appendix 3Z was lodged one business day late due to an administrative oversight. While the market was informed of Mr Tom Stianos’ resignation in a timely manner, there was an inadvertent delay in obtaining and confirming the information required to complete and lodge the Appendix 3Z within the prescribed timeframe.
2. The Company has written procedures in place governing the appointment and resignation of Directors, including procedures designed to ensure compliance with ASX Listing Rule 3.19B and the requirement to lodge an Appendix 3Z no more than five business days after a Director ceases to hold office.
3. The Company considers that the late lodgement is an isolated incident and believes that its current compliance arrangements are adequate and appropriate to ensure compliance with ASX Listing Rule 3.19B.

Yours faithfully,

Kamille Dietrich
Company Secretary
Xref Limited

Xref Limited (ASX:XF1)
ACN 122 404 666
Lv 20, 135 King Street, Sydney, NSW 2000
1Phone: +61 2 8244 3099
Website: xref.com
Email: investors@xref.com

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ASX

13 May 2026

Ms Kamille Dietrich
Company Secretary
Automic Group

By email only.

Dear Ms Dietrich

Xref Limited ('XF1'): Appendix 3Z – Final Director’s Interest Notice Query

ASX refers to the following:

1. XF1’s Appendix 3Z lodged on the ASX Market Announcements Platform ('MAP') on 8 May 2026 for Mr Thomas Stianos (the 'Notice');
2. Listing Rule 3.19A which requires an entity to tell ASX the following:

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.'

The Notice indicates that a change in Mr Stianos’ notifiable interest occurred on 30 April 2026. It appears that the Notice should have been lodged with ASX by 7 May 2026. Consequently, XF1 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.

ASX Limited

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

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1. Please explain why the Appendix 3Z was lodged late.
2. What arrangements does XF1 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 XF1 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 Friday, 15 May 2026. 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, XF1'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 XF1 to request a trading halt immediately.

Your response should be sent to me by e-mail at ListingsComplianceSydney@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 XF1'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 XF1's securities under Listing Rule 17.3.

Listing Rules 3.1 and 3.1A

In responding to this letter, you should have regard to XF1'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 XF1'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

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

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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.

Yours sincerely

ASX Compliance

11084683v1

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