D&O Disclosure

Ongoing Disclosure Notice
Disclosure of Directors and Senior Managers Relevant Interests
Sections 297(2) and 298(2), Financial Markets Conduct Act 2013
To NZX Limited; and
Name of listed issuer:
TRADE WINDOW HOLDINGS
LIMITED ("TWL")
Date this disclosure made:
13/01/2026
Date of last disclosure:
31/12/2025
Director or senior manager giving disclosure
Full name(s):
Albertus Johannes Smith
Name of listed issuer:
Trade Window Holdings Limited
Name of related body corporate (if applicable):
N/A
Position held in listed issuer:
Director & CEO
Summary of acquisition or disposal of relevant interest (excluding specified derivatives)
Class of affected quoted financial products:
Ordinary Shares
Nature of the affected relevant interest(s):
Beneficial Owner
For that relevant interest-
Number held in class before acquisition or disposal:
6,888,694
Number held in class after acquisition or disposal:
6,840,965
Current registered holder(s):
Albertus Johannes Smith
Registered holder(s) once transfers are registered:
Albertus Johannes Smith
Summary of acquisition or disposal of specified derivatives relevant interest (if applicable)
Type of affected derivative:
N/A
Class of underlying financial products:
N/A
Details of affected derivative-
The notional value of the derivative (if any) or the notional amount of underlying financial
products (if any):
N/A
A statement as to whether the derivative is cash settled or physically settled:
N/A
Maturity date of the derivative (if any):
N/A
Expiry date of the derivative(if any):
N/A
The price specified in the terms of the derivative (if any):
N/A
Any other details needed to understand how the amount of the consideration payable
under the derivative or the value of the derivative is affected by the value of the
underlying financial products:
N/A
For that derivative,-
Parties to the derivative:
N/A
If the director or senior manager is not a party to the derivative, the nature of the
relevant interest in the derivative:
N/A
Details of transactions giving rise to acquisition or disposal
Total number of transactions to which notice relates: 9

Details of transactions requiring disclosure-
Date of transaction:
Between 4 January 2026 and 12
January 2026
Nature of transaction:
On-market sale of a total of 47,729
Ordinary Shares in TWL:
4 January 2026:
a) 13,000 at $0.3 each
b) 25,361 at $0.315 each
5 January 2026:
c) 5,364 at $0.315 each
6 January 2026:
d) 1,130 at $0.315 each
7 January 2026
e) 1,027 at $0.315 each
8 January 2026:
f) 908 at $0.315 each
9 January 2026:
g) 24 at $0.315 each
11 January 2026:
h) 791 at $0.315 each
12 January 2026:
i) 124 at $0.315 each
Name of any other party or parties to the transaction (if known):Unknown
The consideration, expressed in New Zealand dollars, paid or received for the
acquisition or disposal. If the consideration was not in cash and cannot be readily by
converted into a cash value, describe the consideration:
NZ$14,840
Number of financial products to which the transaction related: 47,729 Ordinary Shares
If the issuer has a financial products trading policy that prohibits directors or senior
managers from trading during any period without written clearance (a closed period)
include the following details—
Whether relevant interests were acquired or disposed of during a closed period:No
Whether prior written clearance was provided to allow the acquisition or disposal to
proceed during the closed period:
N/A
Date of the prior written clearance (if any):
N/A
Summary of other relevant interests after acquisition or disposal:
Class of quoted financial products:Ordinary Shares
Nature of relevant interest:Beneficial Owner
For that relevant interest,-
Number held in class:6,840,965
Current registered holder(s):Albertus Johannes Smith
For a derivative relevant interest,-
Type of derivative:N/A
Details of derivative,-
The notional value of the derivative (if any) or the notional amount of underlying financial
products (if any):
N/A
A statement as to whether the derivative is cash settled or physically settled:
N/A
Maturity date of the derivative (if any):
N/A
Expiry date of the derivative (if any):
N/A
The price's specified terms (if any):
N/A
Any other details needed to understand how the amount of the consideration payable
under the derivative or the value of the derivative is affected by the value of the
underlying financial products:
N/A
For that derivative relevant interest,-
N/A
Parties to the derivative:
N/A
If the director or senior manager is not a party to the derivative, the nature of the
relevant interest in the derivative:
N/A

Certification
I, 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.
Signature of director or officer:
Date of signature:
12-Jan-26
or
Signature of person authorised to sign on behalf of director or officer:
Date of signature:
Name and title of authorised person: