Avation Regulatory News (AVAP)

NOTIFICATION OF MAJOR HOLDINGS (to be sent to the relevant issuer and to the FCA in Microsoft Word format if possible) i

1a. Identity of the issuer or the underlying issuer of existing shares to which voting rights are attached ii:

Avation PLC

1b. Please indicate if the issuer is a non-UK issuer (please mark with an "X" if appropriate)

Non-UK issuer

2. Reason for the notification (please mark the appropriate box or boxes with an "X")

An acquisition or disposal of voting rights

X

An acquisition or disposal of financial instruments

An event changing the breakdown of voting rights

Other (please specify) iii:

3. Details of person subject to the notification obligation iv

Name

1. Rangeley Capital LLC

2. Christopher C. DeMuth Jr.

(together, "Rangeley")

acting in concert with

3. Jeremy Michael Kersten Raper

City and country of registered office (if applicable)

New Canaan, United States of America

4. Full name of shareholder(s) (if different from 3.) v

Name

Jefferies LLC (in respect of Rangeley)

City and country of registered office (if applicable)

New York, United States of America

5. Date on which the threshold was crossed or reached vi:

18 December 2024

6. Date on which issuer notified (DD/MM/YYYY):

20 December 2024

7. Total positions of person(s) subject to the notification obligation

% of voting rights attached to shares (total of 8. A)

% of voting rights through financial instruments(total of 8.B 1 + 8.B 2)

Total of both in % (8.A + 8.B)

Total number of voting rights held in issuer (8.A + 8.B) vii

Resulting situation on the date on which threshold was crossed or reached

14.90%

N/A

14.90%

9,965,363

Position of previous notification (if

applicable)

15.11%

N/A

15.11%

8. Notified details of the resulting situation on the date on which the threshold was crossed or reached viii

A: Voting rights attached to shares

Class/type ofshares

ISIN code (if possible)

Number of voting rights ix

% of voting rights

Direct

(DTR5.1)

Indirect

 (DTR5.2.1)

Direct

(DTR5.1)

Indirect

(DTR5.2.1)

GB00B196F554

9,965,363

N/A

14.90%

N/A

SUBTOTAL 8. A

9,965,363

14.90%

B 1: Financial Instruments according to DTR5.3.1R (1) (a)

Type of financial instrument

Expirationdate x

Exercise/Conversion Period xi

Number of voting rights that may be acquired if the instrument is

exercised/converted.

% of voting rights

SUBTOTAL 8. B 1

B 2: Financial Instruments with similar economic effect according to DTR5.3.1R (1) (b)

Type of financial instrument

Expirationdate x

Exercise/Conversion Period xi

Physical or cash

Settlement xii

Number of voting rights

% of voting rights

SUBTOTAL 8.B.2

9. Information in relation to the person subject to the notification obligation (please mark the

applicable box with an "X")

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 xiii

Full chain of controlled undertakings through which the voting rights and/or thefinancial instruments are effectively held starting with the ultimate controlling natural person or legal entity (please add additional rows as necessary) xiv

X

Name xv

% of voting rights if it equals or is higher than the notifiable threshold

% of voting rights through financial instruments if it equals or is higher than the notifiable threshold

Total of both if it equals or is higher than the notifiable threshold

Chain 1

Christopher C. DeMuth Jr.

14.70%

N/A

14.70%

Rangeley Capital LLC

14.70%

N/A

14.70%

Chain 2

Jeremy Michael Kersten Raper

0.20%

N/A

0.20%

10. In case of proxy voting, please identify:

Name of the proxy holder

The number and % of voting rights held

The date until which the voting rights will be held

11. Additional information xvi

Rangeley Capital LLC and Jeremy Michael Kersten Raper have a common policy towards the management of the issuer in relation to their respective holdings in the issuer and are therefore to be treated as acting in concert pursuant to DTR 5.2.1(a). As such, the disclosure in sections 7 and 8 of this form reflects their aggregated position.

Place of completion

United States of America

Date of completion

20 December 2024