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SUBSTANTIAL SHAREHOLDERS’ INTERESTS AND SHORT POSITIONS IN THE SHARES
       AND UNDERLYING SHARES OF THE COMPANY

       The register of substantial shareholders required to be kept under section 336 of Part XV
       of the SFO shows that as at 30 September 2019, the Company had been notified of the
       following substantial  shareholders’  interests and  short  positions,  being  5% or  more  of the
       Company’s issued share capital. These interests are in addition to those disclosed above in
       respect of the directors and chief executives.
                                                                     Percentage of
                                                         Number of     the issued
                                    Capacity in which      shares –  share capital
       Name                         shares were held  Long position  of the Company
       Mr LEUNG Kai Ching, Kimen    Beneficial owner     293,000,000      40.51%
        (deceased)                                          (note i)
       Shundean Investments Limited  Beneficial owner    267,812,500      37.03%
                                                            (note i)

       Mr Webb David Michael        Beneficial owner      75,344,884      10.42%
                                                           (note ii)

       Mr LEUNG Wai Lap, David      Beneficial owner      52,280,631       7.23%

       Preferable Situation Assets Limited  Beneficial owner  48,080,841   6.65%
                                                           (note ii)
       Notes:
       (i)   Mr LEUNG Kai Ching, Kimen (deceased) beneficially owned 25,187,500 shares, and in addition he
           held 267,812,500 shares through Shundean Investments Limited, which was 100% directly owned
           by him.
       (ii)   Mr Webb David Michael beneficially owned 27,264,043 shares, and in addition he held 48,080,841
           shares through Preferable Situation Assets Limited, which was 100% directly owned by him.

       Save as disclosed above, as at 30 September 2019, according to the register of interests
       required to be kept by the Company under Section 336 of Part XV of the SFO, there was
       no person, other than the directors of the Company, whose interests are set out in the
       section headed “Directors’ and chief executives’ interests and short positions in the shares,
       underlying shares and debentures of the Company or any associated corporation” above,
       who had any interest or short position in the shares or underlying shares of the Company.
       PURCHASE, SALE OR REDEMPTION OF SHARES

       Neither the Company nor its subsidiary companies has purchased or sold any of the
       Company’s shares for the six months ended 30 September 2019 and the Company did not
       redeem any of its shares during the same period.




                                           Interim Report 2019     ALCO HOLDINGS LIMITED  27
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