SPH Notice – Salt Funds Management Limited

100080615/3821103.1
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
To NZX Limited
and
To Tower Limited
Relevant event being disclosed:
Date of relevant event: 23 October 2019
Date this disclosure made: 25 October 2019
Date last disclosure made: 1 April 2019
Substantial product holder(s) giving disclosure
Full name(s): Salt Funds Management Limited
Summary of substantial holding
Class of quoted voting products: Tower Limited Ordinary Shares (TWR)
Summary for Salt Funds Management Limited
For this disclosure,—
(a) total number held in class: 61,476,815
(b) total in class: 421,647,258
(c) total percentage held in class: 14.580%
For last disclosure,—
(a) total number held in class: 45,223,493
(b) total in class: 337,324,300
(c) total percentage held in class: 13.407%

Details of transactions and events giving rise to relevant event
Salt Funds Management participated in the 1:4 rights issue purchasing a total of
11,969,648 shares for consideration of $6,703,002.88 and participated in the sub-
underwriting purchasing a total of 1,628,567shares for consideration of $911,997.52. In
addition, Salt Funds Management undertook the following transactions as part of normal
on-market trading activities:

100080615/3821103.1


Transaction Type Period Shares/Units Consideration
On-market purchases 29/03/19 – 25/09/19 5,069,585 $(3,597,534.90)
On-market sales 30/04/19 – 16/09/19 -2,414,478 $1,849,396.23
2,655,107


Details after relevant event
Details for Salt Funds Management Limited
Nature of relevant interest(s): Investment Manager
For that relevant interest,—
(a) total number held in class: 61,476,815
(b) total in class: 421,647,258
(c) total percentage held in class: 14.580%
(d) registered holder(s) once transfers are registered: See Annexure 1.
Additional information
Address(es) of substantial product holder(s): Level 3, The Imperial Buildings, 44 Queen
Street, Auckland 1050
Contact details:
Kate Allen, Telephone: 09 869 2933, Email: kate.allen@saltfunds.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: Not applicable.
Certification
I, Kate Allen, 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.

100080615/3821103.1
ANNEXURE 1
SUBSTANTIAL SECURITY HOLDER NOTICE FROM SALT FUNDS MANAGEMENT LTD
DATED 25 October 2019
Name of type of shares Tower Limited Ordinary Shares
Percentage held 14.580%

Registered holder:
Guardian Nominees No.2 Ltd (as custodian for
BT Funds Management (NZ) Ltd)
Holding: 26,926,426 (6.386%)
Registered holder:
National Nominees Ltd (as custodian for Salt
Investment Funds Ltd)
Holding: 16,142,340 (3.828%)
Registered holder:
Trustees Executors Limited (as custodian for
TGH Equities Ltd)
Holding: 1,655,335 (0.393%)
Registered holder:
BNP Paribas Nominees (NZ) Ltd (as custodian for
AMP Capital Investors (New Zealand) Ltd)
Holding: 16,752,714 (3.973%)