ASPEN GROUP — Major Shareholding Notification 2025

Dec 28, 2025

Form 605 Corporations Act Section 671B

Notice of ceasing to be a substantial holder

To: Aspen Group (“APZ”, Ordinary Fully Paid)

1. Details of substantial shareholder

Citigroup Global Markets Australia Pty Limited (ACN 003 114 832) and each of the related bodies corporate in the Citi group of companies worldwide (for more details please visit www.citigroup.com).

The holder ceased being a substantial holder on 23 December 2025.

The previous notice had been given to the company on 22 December 2025.

2. Changes in relevant interests

Particulars of each change in, or change in the nature of, a relevant interest of the substantial holder or an associate in voting securities of the company or scheme, since the substantial holder was last required to give a substantial holding notice to the company or scheme are as follows:

Date ofchange	Person whoserelevant interestchanged andPerson’s votesaffected	Nature of Relevant Interest	Class andnumber ofsecuritiesaffected
23December2025	Citibank, N.A.Sydney Branch	Citibank, N.A. Sydney Branch holds adecreased relevant interest in thesesecurities acting as Agent Lender and asthe holder of securities subject to anobligation to return under a securitieslending agreement. Refer to Annexure A.	- 1,697,952Ordinary FullyPaid
23December2025	Citigroup GlobalMarkets AustraliaPty Limited	Citigroup Global Markets Australia PtyLimited holds a decreased relevantinterest in these securities pursuant tocontracts entered into subject to anobligation to return under a securitieslending agreement**and**pursuant tocontracts entered into in the ordinarycourse of business on a stock market of astock exchange, containing no terms andconditions other than standard terms andconditions. Refer to Annexure A.	-1,751,699Ordinary FullyPaid
23December2025	Citigroup GlobalMarkets Limited	Citigroup Global Markets Limited holds adecreased relevant interest in thesesecurities pursuant to contracts enteredinto subject to an obligation to returnunder a securities lending agreement.Refer to Annexure A.	- 785,000Ordinary FullyPaid

3. Changes in association

The persons who have become associates of, ceased to be associates of, or have changed the nature of their association with, the substantial holder in relation to voting interests in the company or scheme are as follows:

Name and ACN/ARSN(if applicable)	Nature of association
N/A	N/A

4. Addresses

The addresses of persons named in this form are as follows:

Name	Address
Citibank, N.A. Sydney Branch	Two Park2 Park St Sydney, NSW 2000 Australia
Citigroup Global Markets Australia Pty Limited	Two Park2 Park St Sydney, NSW 2000 Australia
Citigroup Global Markets Limited	Citigroup Centre, Canary Wharf33 Canada SquareLondon, E14 5LB, United Kingdom

Dated this day, 29 December 2025.

Briana Mandile

Citigroup Global Markets Australia Pty Limited

T: +61 2 8225 4066

Annexure A

This is Annexure A of 2 pages referred to in Form 605 ‘Notice of ceasing to be a substantial holder’

Schedule (Loan)
Type of Agreement	AMSLA / GMSLA / MSLA
Parties to Agreement	Various
Transfer date	Various
Holder of voting rights	Borrower
Are there any restrictions on voting rights?	No
Scheduled returndate	Unknown
Does the borrower have the right to return**early? **	Yes
If yes, details	Standard AMSLA / GMSLA / MSLA terms
Does the lender have the right to recall**early? **	Yes
Ifyes, details	StandardAMSLA/ GMSLA/MSLAterms
Will the securities be returned onsettlement?	n/a
Statement	If requested by the company to whom theprescribed form must be given, or if requestedby ASIC, Citi will give a copy of the AMSLA /GMSLA/MSLAto the company or ASIC.

Schedule (Agency Lending Agreement)

Type of AgreementParties to AgreementCircumstances under which the agent lendercan exercise the authorisations in relation tothe securitiesCircumstances under which the agent lenderis subject to any restrictions in how it candeal with the securitiesDoes the agent lender have the right to recallearly?If yes, detailsStatement

SecuritiesLendingAgencyAgreement (SLAA)VariousAgent Lender can only exercise authority, asagent, in relation to the lender’s securities asdefined and agreed in the Securities LendingAgencyAgreement.Lenders will define the restrictions and/orsecurities lending parameters in the SecuritiesLending Agency Agreement entered into with thelending agent. Such restrictions/parametersinclude specific designated accounts, lendablelimits, acceptable collateral and/or cashreinvestment guidelines.Agent Lenders have the right to early recall onbehalf of Lender’s instructions. However, theexpectation is the Lender and Borrower wouldhave mutually agreed no sales/recall of thesecurities during the duration of the loan term.Hence, borrowers are not obligated to return thesecurities earlyfortermedloans.Authorised under the standard SecuritiesLending Agency Agreement terms.If requested by the company to whom theprescribed form must be given, or if requestedby ASIC, Citi will give a copy of the authorisationagreement to the company or ASIC.