NZ RegCo Share Price Enquiry Into WDT

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



12 October 2021

John McMahon
Independent Director - Audit & Risk (Chair)
Wellington Drive Technologies Limited

By email: john.mcmahon@auroinvest.com
cc: howard.milliner@wdtl.com
greg.balla@wdtl.com

Wellington Drive Technologies Limited (WDT) – Price Enquiry

Dear John,

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 WDT has increased from $0.124, being the market close price on 30 September 2021,
to $0.162, being the market close price yesterday, 11 October 2021. This represents a gain of
30.6% month-to-date.

Given this price increase, please advise NZ RegCo whether WDT continues to comply with Listing
Rule 3.1.1.

We would appreciate if you could provide NZ RegCo with an answer to the above question (email:
surveillance@nzregco.com) before 1:00pm Tuesday, 12 October 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,




Phil Solarz
Head of Surveillance
NZ RegCo Surveillance

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.

---

®
is a registered Trade Mark of Wellington Drive Technologies

Wellington Drive Technologies Ltd
P: +64 9 477 4500 E: info@wdtl.com
21 Arrenway Drive, Rosedale, Auckland 0632
PO Box 302-533 North Harbour, Auckland 0751, New Zealand
www.wdtl.com



12 October 2021

NZ RegCo
Level 1
11 Cable Street
Wellington 6011

Email: surveillance@nzregco.com
Attention: Phil Solarz, Senior Surveillance Analyst

Dear Phil

Re: Wellington Drive Technologies Limited (WDT) – Price Enquiry

We write in response to NZ RegCo’s letter to WDT dated 12 October 2021. The letter noted an increase in
WDT’s share price of 30.6% from the closing price on 30 September to the closing price on 11 October and
sought advice whether WDT continued to comply with Listing Rule 3.1.1.

WDT advises it has reviewed all information of which it is aware and that it continues to comply with Listing
Rule 3.1.1.



Yours sincerely



Howard Milliner
Company Secretary
Wellington

Drive Technologies Limited