SAPPI LIMITED

Pursuant to the Companies Amendment Act Number 37 of 1999, where securities of an issuer are
registered in the name of a person and that person is not the holder of the beneficial interest in all of the
securities held by the registered shareholder, the registered shareholder is obliged, at the end of every
three-month period to disclose to the issuer the identity of each person on whose behalf the registered
holder holds securities and the number and price of securities issued by that issuer held on behalf of
each such person. We have authorized JP Morgan Cazenove to conduct a monthly investigation into the
beneficial ownership of Sappi Limited shares including those in nominee holdings. All beneficial
holdings are investigated to determine whether there are any shareholders who hold 5% or more of our
shares and these investigations have as of October 1, 2010, revealed the following beneficial holders of
more than 5% of the issued share capital of Sappi Limited:
Name of Shareholder
Number of
Shares Percentage
Public Investment Commissioner (South Africa) ....... 61,609,689 11.9
Further, as a result of these investigations, we have ascertained that some of the shares registered in
the names of the nominee holders are managed by various fund managers and that, as of October 1,
2010, the following fund managers were responsible for 5% or more of the issued share capital of Sappi
Limited.
Number of
Shares
Name of Fund Manager Managed Percentage
Allan Gray Investment Council (South Africa) ........ 116,798,521 22.5
Investec Asset Management (South Africa) .......... 66,968,541 12.9
Capital Group Companies Inc. .................. 43,837,075 8.5
Old Mutual Investment Group (South Africa) ......... 40,244,164 7.7
Under South African law, there is no obligation on the part of our shareholders to disclose to us
arrangements or understandings that may exist between or amongst them with respect to the holding or
voting of shares unless such arrangement or understanding constitutes an affected transaction under
the Securities Regulation Code on Takeovers and Mergers. An ‘‘affected transaction’’ means, among
other things, any transaction which has or will have the effect of vesting control of any company in any
person or two or more persons acting in concert in whom control did not vest prior to such transaction or
scheme. Control is defined with reference to a specified percentage, which is currently 35% of the entire
issued share capital of a company. The major shareholders have no different voting rights.
In November and December 2008, Sappi conducted a renounceable rights offer of 286,886,270
new ordinary shares of ZAR 1.00 each to qualifying Sappi shareholders recorded in the shareholders
register at the close of business on Friday November 21, 2008, at a subscription price of ZAR 20.27 per
rights offer share in the ratio of 6 rights offer shares for every 5 Sappi shares held. The rights offer was
fully subscribed and the shareholders received their shares on December 15, 2008. The rights offer
raised ZAR 5,815,184,693 (approximately US$ 575 million) which was used to partially finance the
Acquisition and related costs.
On December 31, 2008, a e 32 million equivalent in ZAR portion of the Acquisition consideration
was funded through the issue of 11,159,702 ordinary shares of Sappi Limited to M-real Corporation (the
‘‘Consideration Shares’’), with the actual number of such Consideration Shares having been determined
based on the average weighted closing price of the shares and certain adjustments in respect of the
rights offering and other anti-dilutive protections. See Note 33 of the Group Annual Financial Statements
contained elsewhere in this Annual Report.
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