SPH Notice - Harbour Asset Management Limited

Disclosure of beginning to have substantial holding

Section 276, Financial Markets Conduct Act 2013



To NZX Limited

and

To New Zealand Rural Land Company Limited (NZL)
Date this disclosure made: 22 December 2025
Date on which substantial holding
began:
19 December 2025


Substantial product holder(s) giving disclosure
Full name(s):
Harbour Asset Management Limited


Summary of substantial holding
Class of quoted voting
products:
Ordinary Shares (Shares)
Summary for:
Harbour Asset Management Limited
For this
disclosure -
(a) total number held in
class:
7,307,385

(b) total in class: 146,138,526

(c) total percentage held
in class:
5.000%

Details of relevant interests:

Nature of relevant interest(s):
Relevant interest in Shares that FirstCape wholly-owned
subsidiary Harbour Asset Management Limited (Harbour) has a
relevant interest in. Harbour has the power to exercise (or control
the exercise of) rights to vote attached to, and power to acquire
or dispose of (or control the acquisition or disposal of), Shares
under investment powers contained in trust deeds or investment
management agreements with clients, including BNZ Investments
Limited (see below). FirstCape has those powers and controls
indirectly, as the ultimate owner of Harbour.
Number held in class:
7,307,385

Percentage held in class:
5.000%
Current registered holder of
financial products:
For on market purchases: Unknown
For on market sales: Various nominees or custodians for and on
behalf of Harbour Asset Management Limited
Registered holder of financial
products once transfer is
registered:
For on market purchases: Various nominees or custodians for
and on behalf of Harbour Asset Management Limited
For on market sales: Unknown

Details of transactions and events giving rise to substantial holding:

The transactions/events giving rise to this disclosure obligation are on-market buy and sell trades
since 19 August 2025, as summarised in the table below.

Details for: Harbour Asset Management Limited
On-market purchases –
number of shares
533,810
On-market purchases –
gross consideration
$555,303.92
On-market sales – number of shares
652,153
On-market sales – gross consideration
$692,256.02

Additional information
Address of substantial product
holder:
Level 21, 171 Featherston Street, Wellington
Contact details:
Madeleine Pumphrey
M +64 27 376 8309
Madeleine.pumphrey@jbwere.co.nz



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: None.

Certification

I, Madeleine Pumphrey, 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.