NZ RegCo Share Price Enquiry Into Rakon Limited

WGN
Level 1
11 Cable Street
Wellington 6011
New Zealand
PO Box 2959
P +64 4 472 7599
AKL
Level 7, Jarden House
21 Queen Street
Auckland 1010
New Zealand
PO Box 106 555
P +64 9 368 1375



7 January 2021

Maureen Shaddick
Company Secretary
Rakon Limited

By email: maureen.shaddick@rakon.com

Dear Maureen,
Rakon Limited (RAK) – Price Enquiry

We write with respect to the continuous disclosure obligations set out in the Listing Rules (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 (“NZ RegCo”). 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 RAK has increased from $0.61, being the market open price on 6 January 2021 to
$0.74, being the price at 2:45 pm on 7 January 2021. This represents a total increase of $0.13, or
21.3%.

Given this increase in the price of RAK shares, please advise NZ RegCo whether RAK continues to
comply with Listing Rule 3.1.1.

Could you please provide NZ RegCo with an answer to the above question (email:
surveillance@nzregco.com) before 9:00am on Friday, 8 January 2021.

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

Kind Regards,




Rhys Allan
Senior Surveillance Analyst
NZ RegCo

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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Rakon Limited
T +64 9 573 5554, F +64 9 573 5559
8 Sylvia Park Road, Mt Wellington, Auckland 1060, New Zealand
Private Bag 99943, Newmarket, Auckland 1149, New Zealand
Page 1 of 1 w w w . r a k o n . c o m
© 2015 Rakon Limited. All Rights Reserved. Unauthorised use or publication is expressly prohibited.


8 January 2021

NZ Reg Co
Level 7, Jarden House
21 Queen Street
Auckland 1010

Email: surveillance@nzregco.com

Attention: Rhys Allan, Senior Surveillance Analyst
Dear Rhys
Re: Rakon Limited (RAK) – Price Enquiry
We write in response to NZ Reg Co Letter to RAK dated 7 January 2021 noting an increase in RAK
share price of 21.3 % from the opening price on 6 January to 2.45 pm on 7 January and seeking
advice from RAK whether RAK continues to comply with Listing Rule 3.1.1.
RAK advises it has reviewed all information of which it is aware and advises it continues to comply
with Listing Rule 3.1.1.
Yours sincerely

Maureen Shaddick
Company Secretary