SPH Notice – Investment Services Group Ltd

100080615/3821102.1
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
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: 20/10/2020
Date this disclosure made: 21/10/2020
Date last disclosure made: 31/03/2020
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: 31,974,122
(b) total in class: 421,647,258
(c) total percentage held in class: 7.58%
For last 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%
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

100080615/3821102.1
2
For this disclosure,—
(a) total number held in class: 20,906,050

(b) total in class: 421,647,258

(c) total percentage held in class: 4.96%


For last 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%





CUSTODIANUNITS
CITI for private client1,068,205
BNP for private client2,709,912
BNP for private client4,088,534
Northern for private client351,924
BNP for private client2,133,147
MMC for private client1,593,346
JPM for private client6,171,846
JPM for private client975,262
Public Trust for private client1,250,697
BNP for wholesale clients563,177
CUSTODIANUNITS
CITI for private client894,376
BNP for private client2,245,210
BNP for private client4,076,493
Northern for private client349,486
BNP for private client1,790,813
MMC for private client1,311,411
JPM for private client5,764,201
JPM for private client917,259
Public Trust for private client542,311
BNP for wholesale clients214,693

100080615/3821102.1
3
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: 11,068,072

(b) total in class: 421,647,258

(c) total percentage held in class: 2.62%

For last 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%


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
20/06/2020 and 20/10/2020.
Transaction Type Volume
Consideration Paid Consideration Received
Sales 866,359
$502,488.22
CLARITY
BNP for retails clients6,626,186
BNP for retails clients4,015,768
BNP for retails clients426,118
CLARITY
BNP for retails clients3,936,250
BNP for retails clients213,714
BNP for retails clients4,660,000

100080615/3821102.1
4
Purchases 6,047,754
$3,545,913.51


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.