SPH Notice - Accident Compensation Corporation (ACC)

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
To New Zealand Stock Exchange
and
To TOWER Ltd
Relevant event being disclosed: Movement of 1% or more
Date of relevant event: 24 November 2025
Date this disclosure made: 25 November 2025
Date last disclosure made: 1 July 2025
Substantial product holder(s) giving disclosure
Full Name(s): Accident Compensation Corporation (ACC)
Summary of substantial holding
Class of quoted voting products: Ordinary shares (TWR NZ, TWR AU)
Summary for: Accident Compensation Corporation (ACC)
For this disclosure,—
(a) Total number held in class: 23,197,331
(b) Total in class: 342,552,063
(c) Total percentage held in class: 6.772%
For last disclosure,—
(a) Total number held in class: 27,464,356
(b) Total in class: 342,552,063
(c) Total percentage held in class: 8.018%
Details of transactions and events giving rise to relevant event
Details of the transactions or other events requiring disclosure:
From 1 July 2025 to 24 November 2025, ACC had the following aggregated on-market
transactions in TOWER Ltd:
• Sales of 4,267,025 shares for consideration of NZD $7,722,285.30
Details after relevant event
Details for ACC
Nature of relevant interest(s):
Beneficial owner of securities under §235(1)(b) of the Financial Markets Conduct Act
No relevant agreement document needs to be attached under regulation 139.
For that relevant interest,—
(a) Number held in class: 23,197,331
(b) Percentage held in class: 6.772%
(c) Current registered holder(s): ACC via New Zealand Central Securities Depository Limited
(NZCSD)
(d) Registered holder(s) once transfers are registered: unknown

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
Additional information
Address of substantial product holder(s):
ACC: Justice Centre, 19 Aitken Street, PO Box 242, Wellington, NZ
Contact details: Marpessa Hof +64 4 816 6062 investmentscompliance@acc.co.nz
In accordance with the Financial Markets Authority’s Guidance Note: Guidance on Substantial
Product Holder Disclosures issued on 27 September 2017, ACC has not made disclosures for
employees who manage the financial products of which ACC is the beneficial owner.
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: n/a
Certification
I, Marpessa Hof, 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.