Damian Christopher Norris v Insurance Australia Group Limited

This is a group proceeding (class action) brought on behalf of persons who acquired an interest in Insurance Australia Group Limited ( IAG) shares during the period from 25 June 2020 to 20 November 2020, and suffered loss or damage as a result of the defendant ’s alleged conduct.

The claim alleges that IAG made misleading and deceptive representations and breached its continuous disclosure obligations by failing to manage risk/internal controls with regards to business interruption policies (and exclusions) offered by IAG and its subsidiaries, in relation to exposure to the risk of a pandemic such as COVID-19 and paying out related claims.

The claim follows the fall in the price of IAG shares after its corrective disclosure made to the ASX on 20 November 2020, following the decision of HDI Global Speciality SE v Wonkana No. 3 Pty Ltd [2020] NSWCA 296, which found certain pandemic exclusions were not effective to exclude cover for losses. The plaintiff and group members claim loss sustained by purchasing shares in IAG which were inflated in value due to the alleged conduct.

The deadline for opting out and registration has passed.

IMPORTANT INFORMATION ABOUT THE AMENDMENT TO THE GROUP MEMBER DEFINITION

On 3 August 2026, the Court approved a Notice regarding the amendment to the group member definition to be sent to group members. Group members should read the Notice carefully as the matters set out in the notice may affect their legal rights.

Orders of Justice Watson made on 3 August 2026

If there is anything in this notice of which you are unsure, you should:

(1) email the plaintiff

’s solicitors, Quinn Emanuel at iagclassaction@quinnemanuel.com; or (2) seek independent legal advice.

IMPORTANT INFORMATION ABOUT REGISTRATION AND OPTING OUT

The deadline for opting out and registration has passed.

If you are, or you think that you may be a group member, you should read the documents below carefully.

The Notice (a copy of which is below) contains important information about your rights to:

(1) register your claim in the proceeding; or (2) opt out of the proceeding.

In summary, if you fall within the definition of a group member, you have three options:

If you wish to obtain any benefit pursuant to any settlement reached by the parties at any point up until three months after the first day of mediation, you must register your claim in accordance with the Notice by 4.00pm AEDT on 13 March 2025.

To register, you must either: complete the

online registration form with Quinn Emanuel Urquhart & Sullivan; or complete the registration form found at Schedule 1 of the Notice and submit by email or post to the address for Quinn Emanuel Urquhart & Sullivan stated on the form.

For further information on how to register, please refer to Option 1 in the Notice below.

If you do not want your rights determined by the class action you must opt out by 4.00pm AEDT on 13 March 2025.

To opt out, you must either: complete the

online opt out notice; or complete the opt out notice found at Schedule 2 of the Notice and return via email or post to the address for Quinn Emanuel Urquhart & Sullivan stated on the form.

For further information about opting out, please refer to Option 2 in the Notice below.

If you do nothing in response to the Notice you will remain a Group Member of the class action but, subject to any further order of the Court, you will not be entitled to obtain any benefit pursuant to any settlement reached at any point up until three months after the first day of mediation. For further information about this option please refer to Option 3 in the Notice below.

The definition of a "group member" is set out in the Notice.