NZXR Share Price Enquiry into Rubicon Limited

NZX Limited
Level 1, NZX Centre
11 Cable Street
PO Box 2959
Wellington 6140
New Zealand
Tel +64 4 472 7599
www.nzx.com

18 May 2018

Luke Moriarty
Chief Executive
Rubicon Limited

By email: luke.moriarty@rubicon-nz.com


Dear Luke,

Price Enquiry

We write with respect to the continuous disclosure Listing Rules.

Listing Rule 10.1.1 (”the rule”) is set out in the Schedule attached to this letter. In
summary, this rule requires issuers to immediately disclose any Material Information to
NZX Limited (“NZX”). The rule provides limited exceptions to this obligation. Material
Information does not need to be disclosed where a reasonable person would not expect
the information to be disclosed and where the information is confidential and its
confidentiality is maintained and where one of five safe harbours applies.

The price of Rubicon Limited Ordinary Shares (“RBC”) has increased from $0.25, being
the market close price on 16 May 2018, to $0.29, being the market close price on 17
May 2018. This represents a total increase of $0.04, or 16.0%.

The price of Rubicon Limited Ordinary Shares additionally (“RBC”) increased from
$0.25, being the lowest closing price on 16 May 2018, to $0.30, being the highest traded
price on 17 May 2018. This represents a total increase of $0.05, or 20.0%.

Given this increase in the price of RBC, please advise NZX whether Rubicon Limited
continues to comply with Listing Rule 10.1.1.

Could you please provide NZX with an answer to the above question (email:
surveillance@nzx.com) before 1:00pm 18 May 2018.

Please note that Rubicon Limited’s response to this letter will be published in full to the
market.


Yours sincerely,
Market Surveillance

SCHEDULE

10.1.1 Continuous Disclosure of Material Information: Without limiting any other Rule,
every Issuer shall:

(a) once it becomes aware of any Material Information concerning it, immediately
release that Material Information to NZX, provided that this Rule shall not
apply when:

(i) a reasonable person would not expect the information to be disclosed;
and

(ii) the information is confidential and its confidentiality is maintained; and

(iii) one or more of the following applies:

(A) the release of information would be a breach of law; or
(B) the information concerns an incomplete proposal or negotiation; or
(C) the information comprises matters of supposition or is insufficiently
definite to warrant disclosure; or
(D) the information is generated for the internal management purposes
of the Issuer; or
(E) the information is a trade secret.

In this Rule 10.1.1, an Issuer is aware of information if a Director or an
executive officer of the Issuer (and in the case of a Managed Fund, a Director
or executive officer of the Manager) has come into possession of the
information in the course of the performance of his or her duties as a Director
or executive officer.