MKR

Response to ASX Aware Letter

Regulatory11 February 2026MKRMaterials

Manuka Resources Limited - Level 4 Grafton Bond Building, 201 Kent St Sydney NSW Australia 2000
ABN 80 611 963 225 tel +612 7253 2020 www.manukaresources.com.au

10 February 2026






ASX Compliance Pty Limited

Exchange Centre

20 Bridge Street

SYDNEY NSW 2000


By email: listingcompliancesydney@asx.com.au



Manuka Resources Ltd (ASX: MKR) - Response to ASX Aware Letter


Manuka refers to ASX’s letter dated 6 February 2026 (the ASX Aware Letter) requesting information under Listing

Rule 18.7 in relation to recent trading in the securities of Manuka Resources Ltd (Company or MKR).


The Company responds to ASX’s questions as follows, using the same numbering and defined terms referred to in

the ASX Aware Letter.


1. Question 1: Does MKR consider the Information to be information that a reasonable person would

expect to have a material effect on the price or value of MKR’s securities?


Yes, the Company considers the Information included in its Announcement to be information that a

reasonable person would expect to have a material effect on the price or value of the Company' securities.


2. Question 2: If the answer to question 1 is “no”, please advise the basis for that view, commenting

specifically on why MKR sought the suspension of its application to the EPA as mentioned in

paragraph B above, in order to manage its continuous disclosure obligations.


Not applicable.


3. Question 3: When did MKR first become aware of the Information?


On Wednesday, 4 February 2026 at or around 1.12pm (Auckland time) (being 11:12am Sydney time),

the Company's officers received by email a confidential, embargoed draft decision for the Taranaki VTM

Project from New Zealand’s Environmental Protection Authority (EPA) Fast-track Approval expert panel

for comment/review by the Company whilst the EPA was considering when/whether to release it in its

then draft form.


Per discussions with the EPA, the Company understood that the EPA was considering finalising the draft

decision/lifting the embargo and releasing the draft decision on Monday, 9th of February 2026.


4. Question 4: If MKR first became aware of the Information at an earlier time, please explain why

the Information was not released to the market at that earlier time, commenting specifically on

when you believe MKR was obliged to release the information under Listing Rules 3.1 and 3.1A

and what steps MKR took to ensure that the information was released promptly and without delay.

In answering this question, please explain why MKR did not seek a trading halt at an earlier time.


Until such time as the draft decision was released on the Taranaki VTM Project Fast-track website at

6:00pm (Auckland time) on Thursday, 5 February 2026, the potential release of the draft decision in the

form the Company was provided a copy of, was an uncertain event so as not to warrant disclosure. In

short, Company had no certainty as to the form and content that the draft decision would be released in.

As soon as that uncertainty was resolved, the Company immediately made an ASX announcement.


As soon as practicable after the Company was provided the confidential, embargoed draft decision from

the EPA, the Company took the following steps and made the following enquiries to understand the

information:

Manuka Resources Limited - Level 4 Grafton Bond Building, 201 Kent St Sydney NSW Australia 2000
ABN 80 611 963 225 tel +612 7253 2020 www.manukaresources.com.au

(a) review and digest the confidential, embargoed draft decision;

(b) understand the likelihood/timing of the confidential, embargoed draft decision being

amended/varied/superseded prior to announcement;

(c) clarify with the EPA the timing, form and content that any draft decision would be released by the

EPA on the Taranaki VTM Project Fast-track website;

(d) clarify whether any substantive changes would be made to the draft decision before it was released

and prior to it being given to the New Zealand Ministers for comment or becoming a substantive,

non-preliminary or final and binding decision; and

(e) obtain advice from the Company's New Zealand counsel as to its rights of review under the Fast-

track Approvals Act 2024 (NZ).


This occurred during the evening of 4 February and the morning of 5 February 2026, and as such the

Company did not seek a trading halt during the course of trading on Thursday 5 February 2026.


Having taken the steps above, and once the Company understood the nature and impact of the

information (including the likelihood of the confidential, embargoed draft decision being released in its

present form), and in particular, having regard to its continuous disclosure obligations under the ASX

Listing Rules, the Company considered that a draft decision should be released earlier to the market

than Monday, 9th of February 2026. During the evening of 4 February 2026 and 5 February 2026 it

liaised with and sought to clarify with the EPA the above matters and an earlier time of release.


During that time, and given that Friday 6 February 2026 was Waitangi Day, a national public holiday in

New Zealand, the EPA informed the Company that the draft decision would be released on the Taranaki

VTM Project Fast-track website on 5 February 2026 at around 6:00pm (Auckland time), being 4:00pm

(Sydney time).


Accordingly, the draft decision was released on the Taranaki VTM Project Fast-track website at 6:00pm

(Auckland time) on Thursday, 5 February 2026.


ASX may wish to refer to paragraph 5 of Minute 39 of the Expert Panel (which is also published on the

Fast Track website) which records that the draft decision was released to the Ministers and posted on

the Fast Track website at '6pm on Thursday 5 February 2026.' It was at this time that the content of the

draft decision was no longer an uncertainty, but became definitive information which required disclosure.

Immediately on the posting of the draft decision on the Fast Track website, the Company released its

announcement titled, 'Draft Panel Decision to Decline Taranaki VTM Application’, (posted to the Market

Announcement Platform of the ASX at 4:11pm (Sydney time, being 6.11pm Auckland time) on 5

February 2026).


The Announcement states that the Company 'will study the draft panel decision more carefully and

consider its options on what next steps it might take in advance of the application decision being

finalised. Manuka will inform the market further of any steps that TTR intends to take in relation to the

draft panel decision.'


5. Question 5: Does MKR have any explanation for the decrease in price on 5 February 2026 prior to

the release of the Announcement?


The Company is of the view that the decrease in share price of the Company's securities on 5 February

2026 is not related in any way to the draft decision of the EPA’s Fast-track expert panel and the

Information in its Announcement.


Australian listed companies in the gold and silver resource sector experienced similar significant declines

in their security price due to significant declines in gold and silver prices during this period.


6. Question 6: Does MKR consider the Cleansing Notice to have been validly issued? If so, please

explain the basis for that view.


The Company considers that the Cleansing Notice issued on 4 February 2026 at 6.49pm (Sydney time)

to have been validly issued in accordance with section 708A(5)(e) of the Corporations Act.

Until such time as the draft decision of the EPA was released on the Fast Track website on 5 February

2026 at 6pm (Auckland time), following which the Company released its Announcement, the Company

had no reasonable basis to include any further information in its Cleansing Notice.

Manuka Resources Limited - Level 4 Grafton Bond Building, 201 Kent St Sydney NSW Australia 2000
ABN 80 611 963 225 tel +612 7253 2020 www.manukaresources.com.au

7. Question 7: Please confirm that MKR is in compliance with the Listing Rules and, in particular,

Listing Rule 3.1


Confirmed.


8. Question 8: Please confirm that MKR’s responses to the questions above have been authorised

and approved in accordance with its published continuous disclosure policy or otherwise by its

board or an officer of MKR with delegated authority from the board to respond to ASX on

disclosure matters.


Confirmed.



Eryn Kestel

Company Secretary

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