Announcement PDF ASX:ST1 20 December 2023 Dean Litis ASX Compliance Pty Limited Level 50, South Tower, Rialto 525 Collins Street Melbourne VIC 3000 (By email: ListingsComplianceMelbourne@asx.com.au) Dear Dean, SPIRIT TECHNOLOGY SOLUTIONS LTD (ASX: ST1) - PRICE QUERY In reference to your letter of 20 December 2023 regarding the share price and volume of the Company’s securities, the response to your queries in number order is as follows: 1. No. 2. N/A. 3. The Company is aware of a single buyer which appears to have acquired a significant portion of shares, which in the Company’s view appears to be the main reason for the movement in price and volume. The Company also notes that in accordance with its announced strategy it continues to evaluate and conduct due diligence on potential acquisition targets. Those due diligence exercises are at varying stages and may or may not result in binding terms being agreed for those potential targets in the future. The Company will advise the market accordingly if such acquisitions are agreed. 4. It is confirmed that the Company is in compliance with the listing rules, and in particular Listing Rule 3.1. 5. It is confirmed that the responses to the questions above have been authorised and approved by the Board of the Company. Please do not hesitate to contact me if you would like to discuss any of the above matters. Yours sincerely, Melanie Leydin Company Secretary Spirit Technology Solutions ABN 73 089 224 402 spirit.com.au Secure. Sustainable. Scalable. 20 December 2023 Ms Melanie Leydin Company Secretary Spirit Technology Solutions Ltd By email Dear Ms Leydin Spirit Technology Solutions Ltd (‘ST1’): Price - Query ASX refers to the following: A. The change in the price of ST1’s securities from a low of $0.045 yesterday, 19 December 2023 to a high of $0.076 at the time of writing today. B. The significant increase in the volume of ST1’s securities traded during the same period. Request for information In light of this, ASX asks ST1 to respond separately to each of the following questions and requests for information: 1. Is ST1 aware of any information concerning it that has not been announced to the market which, if known by some in the market, could explain the recent trading in its securities? 2. If the answer to question 1 is “yes”. (a) Is ST1 relying on Listing Rule 3.1A not to announce that information under Listing Rule 3.1? Please note that the recent trading in ST1’s securities would suggest to ASX that such information may have ceased to be confidential and therefore ST1 may no longer be able to rely on Listing Rule 3.1A. Accordingly, if the answer to this question is “yes”, you need to contact us immediately to discuss the situation. (b) Can an announcement be made immediately? Please note, if the answer to this question is “no”, you need to contact us immediately to discuss requesting a trading halt (see below). (c) If an announcement cannot be made immediately, why not and when is it expected that an announcement will be made? 3. If the answer to question 1 is “no”, is there any other explanation that ST1 may have for the recent trading in its securities? 4. Please confirm that ST1 is complying with the Listing Rules and, in particular, Listing Rule 3.1. 5. Please confirm that ST1’s responses to the questions above have been authorised and approved under its published continuous disclosure policy or otherwise by its board or an officer of ST1 with delegated authority from the board to respond to ASX on disclosure matters. When and where to send your response This request is made under Listing Rule 18.7. Your response is required as soon as reasonably possible and, in any event, by no later than 2:45pm AEDT Wednesday, 20 December 2023. You should note that if the information requested by this letter is information required to be given to ASX under Listing Rule 3.1 and it does not fall within the exceptions mentioned in Listing Rule 3.1A, ST1’s obligation is to disclose the ASX Limited [[Listings]] #10673025v1 ASX Customer Service Centre 131 279 | asx.com.au information ‘immediately’. This may require the information to be disclosed before the deadline set out in the previous paragraph and may require ST1 to request a trading halt immediately. Your response should be sent to me by e-mail at ListingsComplianceMelbourne@asx.com.au. It should not be sent directly to the ASX Market Announcements Office. This is to allow me to review your response to confirm that it is in a form appropriate for release to the market, before it is published on the ASX Market Announcements Platform. Trading halt If you are unable to respond to this letter by the time specified above, or if the answer to question 1 is “yes” and an announcement cannot be made immediately, you should discuss with us whether it is appropriate to request a trading halt in ST1’s securities under Listing Rule 17.1. If you wish a trading halt, you must tell us: • the reasons for the trading halt; • how long you want the trading halt to last; • the event you expect to happen that will end the trading halt; • that you are not aware of any reason why the trading halt should not be granted; and • any other information necessary to inform the market about the trading halt, or that we ask for. We require the request for a trading halt to be in writing. The trading halt cannot extend past the commencement of normal trading on the second day after the day on which it is granted. You can find further information about trading halts in Guidance Note 16 Trading Halts & Voluntary Suspensions. Suspension If you are unable to respond to this letter by the time specified above, ASX will likely suspend trading in ST1’s securities under Listing Rule 17.3. Listing Rules 3.1 and 3.1A In responding to this letter, you should have regard to ST1’s obligations under Listing Rules 3.1 and 3.1A and also to Guidance Note 8 Continuous Disclosure: Listing Rules 3.1 – 3.1B. It should be noted that ST1’s obligation to disclose information under Listing Rule 3.1 is not confined to, nor is it necessarily satisfied by, answering the questions set out in this letter. Release of correspondence between ASX and entity ASX reserves the right to release all or any part of this letter, your reply and any other related correspondence between us to the market under Listing Rule 18.7A. Yours faithfully ASX Compliance 2/2 ASX Customer Service Centre 131 279 | asx.com.au #10673025v1