BATHURST RESOURCES LIMITED

Shareholders of Bathurst Resources Limited

The 2025 annual report records 239,975,075 fully paid ordinary shares on issue held by 1,784 holders, reported as at 30 September 2025. Only ordinary shares carry voting rights; holders of performance rights have none until exercise. There are no restricted securities or securities subject to voluntary escrow, and no buy-back was on foot.

Because the company is quoted on the ASX, its ownership disclosure runs through the Australian regime — substantial holder notices on Forms 603, 604 and 605 under the Corporations Act 2001 (Cth), together with the ASX Listing Rules — even though the share register itself is a New Zealand one. New Zealand’s own register records the legal holders of shares but imposes no substantial-holding notice duty on this company.

Substantial holdings of 5 percent or more, as recorded by the company from notices received and stated as at 22 September 2025:

• Republic Investment Management Pte Limited – 24,302,437 shares, 10.0 percent
• Crocodile Capital Partners GmbH – 23,168,360 shares, 9.7 percent
• Talley’s Group Limited – 20,659,306 shares, 8.6 percent
• HPRY Holdings Ltd – 12,462,014 shares, 5.2 percent
• Ronald Anthony Ooi Thean Yat – 12,239,586 shares, 5.1 percent

The top-20 register position as at 30 September 2025 reads very differently, because most ASX holdings sit in custodian names:

• BNP Paribas Noms Pty Ltd – 62,275,557 shares, 25.95 percent (custodian)
• Citicorp Nominees Pty Limited – 51,916,198 shares, 21.63 percent (custodian)
• Talleys Group Limited – 20,659,306 shares, 8.61 percent
• HSBC Custody Nominees (Australia) Limited – 14,620,580 shares, 6.09 percent (custodian)
• Kerry (New Zealand) Limited – 11,743,052 shares, 4.89 percent
• PSG Holdings Pte Ltd – 11,743,052 shares, 4.89 percent
• BNP Paribas Nominees Pty Ltd (IB AU Noms Retailclient) – 11,514,607 shares, 4.80 percent (custodian)
• Chng Seng Chye – 9,596,041 shares, 4.00 percent

The 20 largest registered holdings together accounted for 216,257,908 shares, or 90.12 percent of the shares on issue. Two directors appear in the top 20: Richard Tacon (2,100,455 shares, 0.88 percent) and RAMSS Nominees Pty Ltd holding for the Middleton Family Discretionary Account (1,055,108 shares, 0.44 percent).

A custodian such as BNP Paribas, Citicorp Nominees or HSBC Custody Nominees is the registered legal holder of shares it holds for many unrelated underlying clients. It has no economic interest in them and normally votes only on instruction. A custodian line of 25.95 percent on the register is therefore not a 25.95 percent ownership stake and cannot be treated as one for KYB purposes. The beneficial picture is visible only through the substantial holder notices above, where the disclosed holders — Republic Investment Management, Crocodile Capital Partners, Talley’s Group, HPRY Holdings and Mr Ooi — are largely the parties sitting behind those custodian lines.

Ultimate beneficial ownership

No person or entity controls Bathurst Resources Limited. The largest disclosed beneficial holding is 10.0 percent (Republic Investment Management Pte Limited), and no disclosed holder reaches the 25 percent threshold commonly used to identify a beneficial owner. The New Zealand Companies Register records no ultimate holding company for company number 4382538.

Of the disclosed substantial holders, one is a natural person — Ronald Anthony Ooi Thean Yat, 5.1 percent. Nationality is not recorded by the New Zealand Companies Register or stated in the filings reviewed, and is therefore Not disclosed. No date of birth or residential address is published here.

New Zealand does not operate a public register of beneficial owners. The Companies Register publishes legal shareholders and their allocations, but there is no statutory disclosure of the natural persons behind corporate or nominee holders. For this company the practical substitute is the Australian substantial holder regime, which captures relevant interests of 5 percent or more.

Data availability

Ownership above is taken from the shareholder information section of the 2025 annual report (substantial holdings as at 22 September 2025; register and distribution data as at 30 September 2025) and from the New Zealand Companies Register. The 2026 annual report had not been published at the time of writing, and the FY2026 results and financial statements released on 26 August 2026 contain no shareholder information section, so 30 September 2025 remains the most recent published register snapshot.

The dates of individual Forms 603, 604 and 605 are not restated in the annual report; 22 September 2025 is the date at which the company stated its record of substantial shareholdings. Each notice should be read from the ASX announcements platform where an exact lodgement date is required.

The on-file record for this company presented nominee positions as ownership and does not reconcile to the filings. It listed Citicorp Nominees Pty Limited at 17.60 percent (36,596,464 shares) and BNP Paribas Nominees Pty Ltd at 5.37 percent as shareholders; both are custodians, and both figures are superseded by the 30 September 2025 register. It also showed Kerry (New Zealand) Limited at 11.29 percent and PSG Holdings Pte Ltd at 5.65 percent, whereas the annual report shows each holding 11,743,052 shares, being 4.89 percent of the 239,975,075 shares on issue, and HPRY Holdings at 5.99 percent against 5.2 percent in the substantial holder record. The on-file percentages appear to be computed against a smaller share count.

Note also that the stored registration number 9429030288560 is the New Zealand Business Number, not the company number. The company number is 4382538, as confirmed in the corporate directory of the 2025 annual report and on the register. The stored legal form, private limited company, is inaccurate for an ASX-quoted issuer; the register classifies the entity simply as an NZ Limited Company. No ISIN is asserted, because none could be confirmed from an official source: the annual report and financial statements give only the ASX code BRL, and the GLEIF record for LEI 254900H5WZ9DXLTBKY38 carries no mapped ISIN.

Directors and officers of Bathurst Resources Limited

The New Zealand Companies Register records four directors of company number 4382538 as at 24 September 2026. Appointment dates are as held on the register. The register publishes directors’ residential addresses; only the locality is given here.

• Pier Westerhuis — Non-executive Chairman. Director since 29 April 2015. Locality: Fig Tree Pocket, Queensland, Australia. The register records the forename as Pier; the annual report refers to him as Peter Westerhuis.
• Richard Tacon — Executive Director and Chief Executive Officer. Director since 1 April 2015. Locality: Wellington, New Zealand.
• Russell Lee Scott Middleton — Executive Director and Chief Financial Officer. Director since 29 April 2015. Locality: North Turramurra, New South Wales, Australia.
• Francois Dennis Tumahai — Non-executive Director. Director since 4 May 2021. Locality: Hokitika, New Zealand.

The directors’ report in the 2025 annual report lists the same four persons as directors at 30 June 2025 and gives the board roles used above: two non-executive directors (Westerhuis as chairman, Tumahai) and two executive directors (Tacon as chief executive officer, Middleton as chief financial officer). Other current listed-company directorships disclosed in that report: Richard Tacon was appointed a non-executive director of New Talisman Gold Mines Limited in September 2023, and Peter Westerhuis an executive director of Clara Resources Australia Limited in October 2024. No other director holds, or has held in the last three years, a directorship of another listed company.

Larissa Brown is company secretary. That is an officer role, not a directorship, and she is not recorded as a director on the register.

The following senior executives are named in the 2025 annual report. None of them is a director of company number 4382538, and none appears on the register in that capacity: Fiona Bartier, General Manager Health, Safety, Environment and Community; Carmen Dunick, General Manager People and Culture; Sam Johnstone, General Manager Marketing and Logistics; Craig Pilcher, General Manager Domestic Operations; Ian Harvey, General Manager Export Operations; and Sue Bonham-Carter, General Manager Resource Development (Acting).

Recent officer changes

• 4 May 2021 — Francois Dennis Tumahai appointed a director. This is the most recent director appointment on the register, and no appointment or vacation of office has been recorded since.
• 13 November 2014 — David John Frow ceased to hold office as a director.
• 31 March 2014 — Craig Munro ceased to hold office as a director.

Data availability

The board list above is taken from the New Zealand Companies Register for company number 4382538, read on 24 September 2026, and cross-checked against the directors’ report and corporate directory of the 2025 annual report. The register returned intermittent HTTP 500 errors during this work and was retried rather than substituted with an aggregator.

Independence: the 2025 annual report distinguishes executive from non-executive directors but does not state independence designations in the directors’ report. Formal independence assessments are made in the company’s separate corporate governance statement, which was not verified here, so no independence status is asserted for any director.

Nationality is not recorded by the New Zealand Companies Register and is not stated in the filings reviewed. It is therefore Not disclosed for every person named. No date of birth is published, and no residential address is reproduced.

The on-file officer record for this company was stale and conflated two different things. It held 17 rows that mixed the board with management and with directors who left more than a decade ago. Carmen Dunick, shown as Group Manager of People & Culture, and Sam Johnstone, shown as General Manager of Marketing & Logistics with an appointment date of 1 September 2017, are senior managers and not directors; they were presented alongside directors as though equivalent. Richard Tacon was the only row correctly marked as an active director, and the other three current directors were absent from the visible rows, while Craig Munro and David John Frow, who ceased in 2014, were retained. Appointment dates were missing from several rows.

Group structure of Bathurst Resources Limited

Nothing sits above the company. The New Zealand Companies Register records no ultimate holding company for company number 4382538, and the company is the ASX-quoted parent of the group. Its shares are widely held through custodians and disclosed substantial holders, none of which controls it.

BT Mining Limited is not a subsidiary. It is a 65 percent held joint venture. The New Zealand Companies Register confirms the allocation of BT Mining’s 26,000 shares as 16,900 (65.00 percent) to Bathurst Resources Limited and 9,100 (35.00 percent) to Talleys Energy Limited. The financial statements for the year ended 30 June 2026 classify BT Mining as a joint venture rather than a subsidiary, because unanimous approval is required for activities that significantly affect its operations, and account for it using the equity method. BT Mining is therefore excluded from consolidated revenue and assets and appears as a single line: interest in BT Mining of NZD 273.304 million at 30 June 2026 (30 June 2025: NZD 274.606 million), with Bathurst’s share of BT Mining profit of NZD 1.429 million in FY2026 (FY2025: NZD 6.482 million).

This changes how the group should be read. BT Mining owns the mining permits, licences and mining assets at the producing sites — the Buller Plateau operating assets of the Stockton mine in the South Island, and the Rotowaro and Maramarua mines together with certain assets at Huntly West in the North Island. Most of the group’s production therefore sits in a partly owned joint venture that the statutory accounts do not consolidate, which is why consolidated revenue of NZD 20.845 million for FY2026 is far below the NZD 261.0 million the company reports on its unaudited proportionate basis (Bathurst plus 65 percent of BT Mining). It also means a 35 percent third-party interest, Talleys Energy Limited, sits alongside Bathurst in the entity that holds the operating assets.

The group composition note to the FY2026 financial statements lists 11 consolidated subsidiaries, all held 100 percent through ordinary shares, all with a 30 June balance date and all in the coal industry. Two joint ventures are equity accounted: BT Mining Limited at 65 percent and NWP Coal Canada Limited, the Canadian coking coal exploration interest, at 21.8 percent in FY2026 (FY2025: 22.1 percent).

Data availability

Ownership percentages and the subsidiary count come from the group composition note to the financial statements for the year ended 30 June 2026, released with the Appendix 4E on 26 August 2026. Register numbers and statuses for the New Zealand entities were read directly from the New Zealand Companies Register on 24 September 2026, as was the BT Mining shareholding allocation.

Entities not verified against a corporate register: BR Coal Pty Limited (Australia; no ACN obtained and ASIC status not checked) and the Canadian entities Bathurst Resources (NWP) Limited, Bathurst Resources Canada (Holdings) Limited, Bathurst Resources (Telkwa) Limited, Telkwa Mining Limited and NWP Coal Canada Limited (no registration numbers obtained and no Canadian register consulted). For those six, ownership is taken from the accounts and status is unverified.

The four BT Mining Forestry companies were incorporated on 17 December 2025 and so do not appear in the FY2025 group composition note. The register confirms each is held 100 percent by BT Mining Limited, which gives Bathurst an indirect attributable interest of 65 percent. They are not consolidated subsidiaries of Bathurst Resources Limited.

The on-file group tree held 12 nodes and placed all of them, including BT Mining Limited and the four BT Mining Forestry companies, directly beneath Bathurst Resources Limited as though they were subsidiaries. That is wrong for five of the twelve: those five are held through a 65 percent equity-accounted joint venture. The on-file tree also omitted BR Coal Pty Limited and all five Canadian entities, so it understated the group’s international footprint while overstating the extent of New Zealand control. Name spelling also varies: the register and the FY2026 statements use New Brighton Collieries Limited, while the FY2025 statements spelled it Colleries.

New Zealand has no public register of beneficial owners, so no layer of natural-person ownership above this structure is available from an official New Zealand source.