NZXR Share Price Enquiry into Comvita 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

23 September 2019

Lisa Blackstock
General Manager Finance
Comvita Limited

By email: Lisa.Blackstock@comvita.com
CC: brett.hewlett@comvita.com

Dear Lisa,

Price Enquiry

We write with respect to the continuous disclosure Listing Rules.

Listing Rule 3.1.1 (”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 Comvita Ordinary Shares (“CVT”) has increased from $2.71, being the market close
price on 19 September 2019, to $3.29, being the current price at 2:30pm on 23 September 2019.
This represents an increase of 21.4%.

Given this price increase, please advise NZX whether Comvita Limited continues to comply with
Listing Rule 3.1.1.

Could you please provide NZX with an answer to the above question (email:
surveillance@nzx.com) before 9:30am tomorrow, 24 September 2019.

Please provide your response to this letter in “PDF” format, and note that it will be published in
full to the market.


Yours sincerely,

Alistair Weekes
NZX Market Surveillance
04 495 2829

2

SCHEDULE

3.1 Disclosure of Material Information
3.1.1 Once an issuer becomes Aware of any Material Information relating to it, the Issuer must:
a) Promptly and without delay release that Material Information through MAP, and
b) Not disclose any Material Information to the public, any other stock exchanges (except as
provided for in Rule 3.26.2(d)) or any other party without first releasing that Material
Information through MAP.

3.1.2 Rule 3.1.1 does not apply when:
(a) One or more of the following applies:
i) Release of the information would be a breach of the law,
ii) The information concerns an incomplete proposal or negotiation,
iii) The information contains matters of supposition or is insufficiently definite to warrant
disclosure
iv) The information is generated for internal management purposes, or
v) The information is a trade secret,
(b) The information is confidential and its confidentiality is maintained, and
(c) A reasonable person would not expect the information to be disclosed.

3.2 False Market
3.2.1 An Issuer must promptly and without delay release Material Information through MAP to
the extent necessary to prevent development or subsistence of a market for its Quoted
Financial Products which is materially influenced by false or misleading information
emanating from:
a. the Issuer or any Associated Person of the Issuer, or
b. other persons in circumstances in each case which would give such information
substantial credibility,
and which is of a reasonably specific nature whether or not Rule 3.1.2 applies.

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24 September 2019

Alistair Weekes
NZX Market Surveillance

By email: surveillance@nzx.com

Dear Alistair,

Comvita Limited – Price Enquiry

I refer to your letter dated 23 September 2019.

I can confirm that Comvita Limited continues to comply with Listing Rule 3.1.1.

Yours sincerely



Brett Hewlett
Executive Director
Comvita Limited