Headlam Regulatory News (HEAD)

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

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

Headlam Group 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):

3. Details of person subject to the notification obligation

Name

Ruffer LLP

City and country of registered office (if applicable)

London, United Kingdom

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

Name

City and country of registered office (if applicable)

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

18 September 2018

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

19 September 2018

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 of issuer

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

Less than 5%

0%

Less than 5%

84,587,131

Position of previous notification (if

applicable)

5%

0%

5%

8. 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 ofshares

ISIN code (if possible)

Number of voting rights

% of voting rights

Direct

(Art 9 of Directive 2004/109/EC) (DTR5.1)

Indirect

(Art 10 of Directive 2004/109/EC) (DTR5.2.1)

Direct

(Art 9 of Directive 2004/109/EC) (DTR5.1)

Indirect

(Art 10 of Directive 2004/109/EC) (DTR5.2.1)

GB0004170089

4,225,172

0

Less than 5%

0%

SUBTOTAL 8. A

4,225,172

Less than 5%

B 1: Financial Instruments according to Art. 13(1)(a) of Directive 2004/109/EC (DTR5.3.1.1 (a))

Type of financial instrument

Expirationdate

Exercise/Conversion Period

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

exercised/converted.

% of voting rights

N/A

N/A

N/A

N/A

N/A

SUBTOTAL 8. B 1

N/A

N/A

B 2: Financial Instruments with similar economic effect according to Art. 13(1)(b) of Directive 2004/109/EC (DTR5.3.1.1 (b))

Type of financial instrument

Expirationdate

Exercise/Conversion Period

Physical or cash

settlement

Number of voting rights

% of voting rights

N/A

N/A

N/A

N/A

N/A

N/A

SUBTOTAL 8.B.2

N/A

N/A

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

X

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)

Name

% 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

N/A

N/A

N/A

N/A

10. In case of proxy voting, please identify:

Name of the proxy holder

N/A

The number and % of voting rights held

N/A

The date until which the voting rights will be held

N/A

11. Additional information

Ruffer LLP now controls the voting rights over 4,225,172 shares (less than 5% of the voting rights) of Headlam Group plc which are held by the discretionary clients of Ruffer LLP and its subsidiaries (the voting of which is all controlled by Ruffer LLP).

This change from 5% to less than 5% is due to the sale of 50,000 shares by Ruffer LLP on 18 September 2018.

Place of completion

Ruffer LLP

Date of completion

19/09/18