Aperam S.A.

Major Shareholding Notification • Jan 7, 2022

ANNEXE A: Standard form for notification of major holdings

Form to be used for the purposes of notifying a change in major holdings pursuant to the amended law and Grand-ducal Regulation of 11 January 2008 on transparency requirements for issuers of securities (referred to as "the Transparency Law" and "the Transparency Regulation")

NOTIFICATION OF MAJOR HOLDINGS (to be sent to the relevant issuer and to the CSSF)

1. Identity of the issuer or the underlying issuer of existing shares to which voting rights are
attachedi:
Aperam	24-26, Boulevard d'Avranches, L - 1160 Luxembourg
RCS Luxembourg : B 155.908
		2. Reason for the notification (please tick the appropriate box or boxes):
	_J An acquisition or disposal of voting rights
	_J An acquisition or disposal of financial instruments
	_J An event changing the breakdown of voting rights
		[ Other (please specify)": Change in intermediate holding structure
	3. Details of person subject to the notification obligation :
Name: HSBC Trustee (C.I.) Limited
acting as trustee of the Platinum
Settlement and the Silver Settlement of which Mr. Lakshmi N. Mittal and Mrs.
Usha Mittal are the beneficiaries, along		City and country of registered office (if applicable): /
with their children and of which Mr.
Lakshmi N. Mittal is the protector.
4. Full name of shareholder(s) (if different from 3.):
Value Holdings II S.à r.l., a limited liability company organized under the laws of Luxembourg, 6, rue Eugène Ruppert, L-2453 Luxembourg, RCS Luxembourg: B 213.703
5. Date on which the threshold was crossed or reached":
23 December 2021
6. Total positions of person(s) subject to the notification obligation:
		% of voting rights
	% of voting rights	through financial	Total of both in %	Total number of
	attached to shares	instruments	(7.A + 7.B)	voting rights of
	(total of 7.A)	(total of 7.B.1 +		issuer
		7.B.2)

Commission de Surveillance du Secteur Financier

Resulting situation on the date on which threshold was crossed or reached	39.8859 %	N/A %	N/A %	79,996,280
Position of previous notification (if applicable)	40.6702 %	4.9190 %	45.5892 %

7. Notified details of the resulting situation on the date on which the threshold was crossed or reached™:

A: Voting rights attached to shares

Class/type of	Number of voting rights™	% of voting rights
shares ISIN code (if possible)	Direct (Art 8 of the Transparency Law)	Indirect (Art 9 of the Transparency Law)	Direct (Art 8 of the Transparency Law)	Indirect (Art 9 of the Transparency Law)
LU0569974404	13,340	31,893,992	0.0166 %	39.8693 %
			0/0	0/0
			0/0	%
SUBTOTAL A (Direct & Indirect)		31,907,332		39.8859 %

B 1: Financial Instruments according to Art. 12(1)(a) of the Transparency Law Number of
Type of financial instrument	Expiration dater	Exercise/ Conversion Period*	voting rights that may be acquired if the instrument is exercised/ converted.	% of voting rights
				%
				%
				%
		SUBTOTAL B.1		0%

du Secteur Financier

B 2: Financial Instruments with similar economic effect according to Art. 12(1)(b) of the Transparency Law

Type of financial instrument	Expiration dateˣ	Exercise/ Conversion Period **	Physical or cash settlement™	Number of voting rights	% of voting rights
					%
					%
					%
			SUBTOTAL B.2		%

1. Information in relation to the person subject to the notification obligation: (please tick the applicable box)

[] Person subject to the notification obligation is not controlled by any natural person or legal entity and does not control any other undertaking(s) holding directly or indirectly an interest in the (underlying) issuer."

2 Eull chain of controlled undertakings through which the voting rights and/or the financial instruments are effectively held starting with the ultimate controlling natural person or legal entity™ (please provide a separate organisational chart in case of a complex structure):

No	Name™	% of voting rights held by ultimate controlling person or entity or held directly by any subsidiary if it equals or is higher than the notifiable threshold	% of voting rights through financial instruments held by ultimate controlling person or entity or held directly by any subsidiary if it equals or is higher than the notifiable threshold	Total of both	Direct V contro lled by (use numb er(s) from નું રા colum n)
1	Mr. Lakshmi N. Mittal and Mrs. Usha Mittal	0.0166 %	N/A %	0.0166 %	N/A
2	Platinum Settlement and Silver Settlement	N/A%	N/A %	N/A %	1
3	Grandel II PTE. Ltd.	N/A%	N/A%	N/A%	2

Commission de Surveillance du Secteur Financier

ব	Value Holdings II S.à r.l.	39.8693 %		N/A %	39.8693 %	3
	9. In case of proxy voting: The proxy holder named	will cease to hold	% and	number of voting rights as of

10. Additional information™:

All the shares held by the Platinum Settlement and the Silver Settlement in Grandel II Limited (company registration no. 115367), a company incorporated under the laws of Gibraltar, with its registered office at 57/63 Line Wall Road, Gibrallar, Gibrallar, have on 23 December 2021 been transferred to Grandel II PTE. Ltd., (company registration no. 202143364W), a company incorporated under the laws of Singapore, with its registered office at 101 Cecil street, #18-08, Tong Eng building, Singapore 069533, by way of a share for share exchange. On the same day, all the shares in Value Holdings II S.à r.1. held by Grandel II Limited have been transferred to Grandel II PTE. Ltd.

Done in	Luxembourg		7 January 2022
By: Philippe Hoss		ـــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــ

For and on behalf of HSBC Trustee (C.I.) Limited as trustee of the trusts referred to in section 3 above

Notes

i Please note that national forms may vary due to specific national legislation (Article 3(1a) of Directive 2004/109/EC) as for instance the applicable thresholds or information regarding capital holdings.

4 Full name of the legal entity and further specification of the issuer or underlying issuer, provided it is reliable and accurate (e.g. address, LEI, domestic number identity).

™ Other reason for the notification could be voluntary notifications, changes of attribution of the holding (e.g. expiring of financial instruments) or acting in concert.

ir This should be the full name of (a) the natural person or legal entity acquiring, disposing of or exercising voting rights in the cases provided for in Article 9 (b) to (h) of the Transparency Law; or (c) the holder of financial instruments referred to in Article 12(1) of the Transparency Law.

As the disclosure of cases of acting in concert may vary due to the specific circumstances (e.g. same or different total positions of the parties, entering or exting of acting in concert by a single party) the standard form does not provide for a specific method how to notify cases of acting in concert.

In relation to the transactions referred to in points (b) to (h) of Article 9 of the Transparency Law, the following list is provided as indication of the persons who should be mentioned:

12899715 3

• in the circumstances foreseen in letter (b) of Article 9 of that Law, the natural person or legal entity that acquires the voting rights and is entitled to exercise them under the natural person or legal entity who is transfering temporarily for consideration the voting rights;

• in the circumstances foreseen in letter (c) of Article 9 of that Law, the natural person or legal entity holding the collateral, provided the person or entity controls the voting rights and declares its intention of exercising them, and natural person or legal entity lodging the collateral under these conditions;

• in the circumstances foreseen in letter (d) of Article 9 of that Law, the natural person or legal entity who has a life interest in shares if that person or entity is entitled to exercise the voting rights attached to the shares and the natural person or legal entity who is disposing of the voting rights when the life interest is created;

• in the circumstances foresen in letter (e) of Article 9 of that Law, the controlling natural person or legal entity and, provided it has a notification duty at an individual level under letters (a) to (d) of Article 9 of that Law or under a combination of any of those situations, the controlled undertaking;

• in the circumstances foresen in letter (f) of Article 9 of that Law, the shares, if he can exercise the voling rights attached to the shares deposited with him at his discretion, and the shares allowing the deposit taker to exercise the voting rights at his discretion;

• in the circumstances foreseen in letter (g) of Article 9 of that Law, the natural person or legal entity that controls the voting rights:

• in the circumstances foreseen in letter (h) of Article 9 of that Law, the can exercise the voting rights at his discretion, and the shareholder who has given his proxy holder allowing the latter to exercise the voling rights at his discretion (e.g. management companies).

* Applicable in the cases provided for in Article 9 (b) to (h) of the Transparency Law. This should be the full name of the shareholder who is the counterparty to the natural person or legal entity referred to in Article 9 of that Law unless the percentage of voting rights held by the shareholder is lower than the 5% threshold for the disclosure of voling rights holdings (e.g. identification of funds managed by management companies).

w The date on which threshold is crossed or reached should be the date on which the acquisition or disposal took place or the other reason triggered the notification obligation. For passive crossings, the date when the corporate event took effect.

w The total number of voling rights shall be composed of all the shares, including depository receipts representing shares, to which voting rights are attached even if the exercise thereof is suspended.

wilt the holding has fallen below the 5% threshold, please note that it is not necessary to disclose the extent of the holding, only that the new holding is below that threshold.

i* In case of combined holdings of shares with voting rights attached "direct holding" please split the voting rights number and percentage into the direct columns - if there is no combined holdings, please leave the relevant hox blank.

* Date of maturity/expiration of the financial instrument i.e. the date when right to acquire shares ends.

™ If the financial instrument has such a pease specify this period – for example once every 3 months starting from [date].

** In case of cash settled instruments the number and percentages of voling rights is to be presented on a delta-adjusted basis (Article 12(2) of the Transparency Law).

in if the person subject to the notification obligation is either control and/or does control another undertaking then the second option applies.

Commission de Surveillance du Secteur Financier

** The full chain of controlled undertakings starting with the ultimate controlling natural person or legal entity also has to be presented in the cases in which only on subsidiary level a threshold is crossed or reached and the subsidiary undertaking discloses the notification as only then the market always gets the full picture of the group holdings. In case of multiple chains through which the voting rights and/or financial instruments are effectively held the chains have to be presented chain by chain leaving a row free between different chains (e.g.: A, B, C, free row, A, E, F etc.). Numbers shall be attributed to all persons or entities within the group in column 1 in order to allow a clear indication of the control structure in column 6. The names of all undertakings of the control chain shall be provided in column 2, even if the directly held voting rights and/or financial instruments is not equal or higher than the notifiable threshold. Columns 3 & 4 shall indicate the holdings of those persons or entities directly holding the voting rights and/or financial instruments if the holding is equal or higher than the notifiable threshold.

** The names of controlled undertakings through which the voting rights and/or financial instruments are effectively held have to be presented irrespectively whether the controlled undertakings cross or reach the threshold themselves.

xvi Example: Correction of a previous notification.