Announcement PDF 10 October 2024 Reference: 101261 Mr Christopher Healy Company Secretary Titomic Limited Level G, 365 Ferntree Gully Road Mount Waverley VIC 3149 By email: chris.healy@titomic.com Dear Mr Healy Titomic Limited (‘TTT’): Aware Query ASX refers to the following: A. TTT’s response to ASX’s query letter, published on the ASX Market Announcements Platform (‘MAP’) on 10 September 2024 which stated in relation to whether a sale of a single D523 unit worth $72,000 was material to TTT: “No. The Announcement was the subject of an internal administrative error and was incorrectly marked as market sensitive during the lodgement process on ASX Online. The Company has undertaken an internal audit of its processes and systems with ASX announcements to ensure that administrative errors, like this one, will not reoccur. Further, the Company notes that that the Announcement did not, in fact, have a material effect on the price or value of TTT's securities.” B. TTT’s announcement titled ‘Titomic makes first sale of a D623 in Australia’ lodged on MAP on 26 September 2024 (the ‘D623 Announcement), disclosing the sale of a Titomic D623 cold spray system to United Industrial Solutions for a consideration of $174,000 (the ‘D623 Information’). C. TTT’s announcement titled ‘Titomic introduces augmented reality enhancement for D523’ lodged on MAP on 9 October 2024 (the ‘D523 Announcement), disclosing the ‘impending launch’ of its Augmented Reality software suite for its D523 portable cold spray system (the ‘D523 Information’). D. The definition of ‘aware’ in Chapter 19 of the Listing Rules. This definition states that: ‘an entity becomes aware of information if, and as soon as, an officer of the entity (or, in the case of a trust, an officer of the responsible entity) has, or ought reasonably to have, come into possession of the information in the course of the performance of their duties as an officer of that entity.’ Additionally, you should refer to section 4.4 in Guidance Note 8 Continuous Disclosure: Listing Rules 3.1 – 3.1B ‘When does an entity become aware of information’. E. Listing Rule 3.1A, which sets out exceptions from the requirement to make immediate disclosure, provided that each of the following are satisfied. ‘3.1A Listing rule 3.1 does not apply to particular information while each of the following requirements is satisfied in relation to the information: 3.1A.1 One or more of the following 5 situations applies: • ASX Limited [[Listings]] #10805526v1 It would be a breach of a law to disclose the information; ASX Customer Service Centre 131 279 | asx.com.au • The information concerns an incomplete proposal or negotiation; • The information comprises matters of supposition or is insufficiently definite to warrant disclosure; • The information is generated for the internal management purposes of the entity; or • The information is a trade secret; and 3.1A.2 The information is confidential and ASX has not formed the view that the information has ceased to be confidential; and 3.1A.3 A reasonable person would not expect the information to be disclosed.’ F. Section 4.15 of Guidance Note 8, which states (relevantly): “Entities should not use an announcement under Listing Rule 3.1 as a guise to publish material that is really promotional, political or tendentious in nature rather than being information that a reasonable person would expect to have a material effect on the price or value of its securities.” G. Section 7.10 of Guidance Note 8, which states (relevantly): “ASX is alive to listed entities making market announcements with a view to “ramping up” the price of their securities. Ramping announcements come in many forms, including: … an announcement that an entity has entered into what appears to be a material contract or transaction but without disclosing key information that investors and their professional advisers reasonably need to understand the materiality of the contract or transaction and to assess its impact on the price or value of the entity's securities. • The last example above occurs not infrequently in the context of announcements about customer contracts. Some examples that ASX has observed include an entity: … describing a customer contract as "material" or with other superlatives when plainly it is not.” • Request for information Having regard to the above, ASX asks TTT to respond separately to each of the following questions and requests for information. The D623 Announcement 1. Does TTT consider the D623 Information contained in the D623 Announcement to be information that a reasonable person would expect to have a material effect on the price or value of its securities? Please explain the basis for that view. 2. If the answer to question 1 is “yes”: 2.1 When did TTT become aware of the D623 Information? 2.2 Please explain the basis for that view, commenting specifically on the materiality thresholds used by TTT to differentiate between the D623 Information and the sale referred to at paragraph A. 2/4 ASX Customer Service Centre 131 279 | asx.com.au #10805526v1 3. If the answer to question 1 is “no”: 3.1 Please advise why TTT indicated the D623 Announcement to be ‘market sensitive’ when it was lodged on MAP, commenting specifically on TTT’s ‘internal audit’ undertaken to ensure these errors would not reoccur. 3.2 Please explain the Listing Rule or Corporations Act basis necessitating lodging the announcement on MAP. 3.3 If TTT considers it complied with section 7.10 of Guidance Note 8 concerning ramping announcements, please explain the basis for that view. The D523 Announcement 4. Does TTT consider the D523 Information contained in the D523 Announcement to be information that a reasonable person would expect to have a material effect on the price or value of its securities? 5. If the answer to question 4 is “yes”: 5.1 Please explain the basis for that view, noting that the augmented reality software does not appear to have launched yet. 5.2 Please confirm when TTT anticipates this launch to occur. 6. If the answer to question 4 is “no”: 6.1 Please advise why TTT indicated the D523 Announcement to be ‘market sensitive’ when it was lodged on MAP, commenting specifically on TTT’s ‘internal audit’ undertaken to ensure these errors would not reoccur. 6.2 Please explain the Listing Rule or Corporations Act basis necessitating lodging the announcement on MAP. 6.3 If TTT considers it complied with section 7.10 of Guidance Note 8 concerning ramping announcements, please explain the basis for that view. General 7. Please confirm that TTT complying with the Listing Rules and, in particular, Listing Rule 3.1. 8. Please confirm that TTT’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 TTT 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 5:00 PM AEST Tuesday, 15 October 2024. 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, TTT’s obligation is to disclose the information ‘immediately’. This may require the information to be disclosed before the deadline set out in the previous paragraph and may require TTT 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. 3/4 ASX Customer Service Centre 131 279 | asx.com.au #10805526v1 Trading halt If you are unable to respond to this letter by the time specified above, you should discuss with us whether it is appropriate to request a trading halt in TTT’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 TTT’s securities under Listing Rule 17.3. Listing Rules 3.1 and 3.1A In responding to this letter, you should have regard to TTT’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 TTT’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. Regards ASX Compliance 4/4 ASX Customer Service Centre 131 279 | asx.com.au #10805526v1