Apportionment of Expenditure for South African Tax Purposes in Respect of the Unbundling ASTRAPAK LIMITED Incorporated in the Republic of South Africa (Registration number 1995/009169/06) Share code: APK ISIN: ZAE000096962 Share code: APKP ISIN: ZAE000087201 (“Astrapak” or “the Company”) APPORTIONMENT OF EXPENDITURE FOR SOUTH AFRICAN TAX PURPOSES IN RESPECT OF THE UNBUNDLING OF THE SHARES IN MASTER PLASTICS TO ASTRAPAK SHAREHOLDERS 1. INTRODUCTION Astrapak Shareholders are referred to: 1.1 the following announcements released on SENS: - the joint firm intention announcement dated 15 December 2016 regarding, inter alia: o the Offer by RPC to acquire, either itself or through RPC Nominee, all of the Astrapak Ordinary Shares, excluding the 12 837 424 Treasury Shares and 1 258 594 Astrapak Ordinary Shares held by the ASOS Trust, being a total of 121 035 232 Astrapak Ordinary Shares, as well as the voluntary repurchase by Astrapak of all of the Preference Shares in issue from the holders thereof, both by way of schemes of arrangement in terms of section 114 of the Companies Act proposed by the Astrapak Board to the Astrapak Shareholders; and o the unbundling of all the shares in Master Plastics to Astrapak Ordinary Shareholders by way of a distribution in specie in terms of section 46(1)(a)(ii) of the Companies Act and section 46 of the Income Tax Act (the “Unbundling”), and the separate listing of the issued shares of Master Plastics on the AltX (the “Listing”), both of which were subject to the passing of all the resolutions that were to be voted upon in terms of the circular to Astrapak Shareholders (“Circular”); - the results of the General Meeting of Astrapak Shareholders, the Preference Share Scheme Meeting and the Ordinary Share Scheme Meeting announcement dated 12 May 2017 confirming all resolutions were duly passed at the meetings and consequently that the Unbundling and Listing have become unconditional; and 1.2 the Circular distributed to Astrapak Shareholders on 7 April 2017. Terms defined in the aforementioned announcements and in the Circular shall, unless otherwise stated, bear the same meaning in this announcement. The purpose of this announcement is to notify Astrapak Shareholders of the apportionment percentage to be applied by Astrapak Ordinary Shareholders to determine the amount of the expenditure or base cost (as applicable) for their Astrapak Ordinary Shares to be allocated to the unbundled Master Plastics Shares and the amount by which the expenditure or base cost (as applicable) for their Astrapak Ordinary Shares should be reduced. 2. APPORTIONMENT TAX PRINCIPLES Astrapak Ordinary Shares held as trading stock: Any Astrapak Ordinary Shareholder holding Astrapak Ordinary Shares as trading stock will be deemed to have acquired the unbundled Master Plastics Shares as trading stock. The expenditure of such Astrapak Ordinary Shares for purposes of the apportionment will be the amount originally taken into account by the Astrapak Ordinary Shareholder in respect of those Astrapak Ordinary Shares, as contemplated in section 11(a), section 22(1) or section 22(2) of the Income Tax Act. The portion of the above expenditure to be allocated to the unbundled Master Plastics Shares is determined by applying the ratio that the market value of the Master Plastics Shares bears to the sum of the market value of Astrapak Ordinary Shares and Master Plastics Shares at the end of the day of the Unbundling, being 24 May 2017 ("Unbundling Date") to such expenditure. The expenditure so allocated to the unbundled Master Plastics Shares will reduce the expenditure relating to the Astrapak Ordinary Shares. Astrapak Ordinary Shares held as capital assets: Any Astrapak Ordinary Shareholder holding Astrapak Ordinary Shares as capital assets will be deemed to have acquired the unbundled Master Plastics Shares as capital assets. The base cost of such Astrapak Ordinary Shares for purposes of the apportionment will be the original expenditure incurred in respect of the Astrapak Ordinary Shares, in terms of paragraph 20 of the Eighth Schedule to the Income Tax Act, and where the Astrapak Ordinary Shares were acquired before 1 October 2001, the market value on valuation date adopted or determined as contemplated in paragraph 29 of the Eighth Schedule to the Income Tax Act. The portion of the above base cost to be allocated to the unbundled Master Plastics Shares is determined by applying the ratio that the market value of the Master Plastics Shares bears to the sum of the market value of Astrapak Ordinary Shares and Master Plastics Shares at the end of the day of the Unbundling Date to such base cost. The base cost so allocated to the unbundled Master Plastics Shares will reduce the base cost of the Astrapak Ordinary Shares. Astrapak Ordinary Shareholders are advised to consult their own tax advisors should they have any queries regarding the taxation consequences of the Unbundling and the calculation of their expenditure and / or base cost (as applicable) of the Astrapak Ordinary Shares and Master Plastics Shares for taxation purposes. 3. APPORTIONMENT RATIO Astrapak Ordinary Shareholders are hereby advised that 9.54% of the expenditure and / or base cost (as applicable) of each Astrapak Ordinary Share must be allocated to each Master Plastics Share and the expenditure and / or base cost (as applicable) to each Astrapak Ordinary Share reduced by such amount. The Apportionment Ratios are based on the closing price of R7.30 per Astrapak Ordinary Share and R0.77 per Master Plastics Share at the end of the day of Unbundling Date. Johannesburg 25 May 2017 Corporate Advisor and Transaction Sponsor to Astrapak Merchantec Capital Legal Advisor and Tax Advisor to Astrapak Webber Wentzel Date: 25/05/2017 12:20:00 Produced by the JSE SENS Department. The SENS service is an information dissemination service administered by the JSE Limited ('JSE'). The JSE does not, whether expressly, tacitly or implicitly, represent, warrant or in any way guarantee the truth, accuracy or completeness of the information published on SENS. 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