Phoenix Group Holdings Regulatory News (PHNX)

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:

Phoenix Group Holdings

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

Non-UK issuer

X

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

An acquisition or disposal of voting rights

An acquisition or disposal of financial instruments

An event changing the breakdown of voting rights

Other (please specify)iii: This is a corrective disclosure to highlight the full 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 detailed within Section 9.

In addition, disclosures at underlying intermediate holding company levels have previously not been submitted. However, disclosures have previously been submitted at the required aggregated parent level of Standard Life Aberdeen plc's affiliated investment management entities with delegated voting rights on behalf of multiple managed portfolios.

X

3. Details of person subject to the notification obligation

Name

Aggregate of Standard Life Aberdeen plc affiliated investment management entities with delegated voting rights on behalf of multiple managed portfolios

City and country of registered office (if applicable)

Edinburgh, Scotland

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

Name

City and country of registered office (if applicable)

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

11/07/2018

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

12/07/2018

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 issuervii

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

8.71

0.00

8.71

570,112,058

Position of previous notification (if

applicable)

7.99

0.00

7.99

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

A: Voting rights attached to shares

Class/type ofshares

ISIN code (if possible)

Number of voting rightsix

% 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)

KYG7091M1096

N/A

49,671,296

N/A

8.71

SUBTOTAL 8. A

49,671,296

8.71

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

Type of financial instrument

Expirationdatex

Exercise/Conversion Periodxi

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 Art. 13(1)(b) of Directive 2004/109/EC (DTR5.3.1.1 (b))

Type of financial instrument

Expirationdatex

Exercise/Conversion Period xi

Physical or cash

settlementxii

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) issuerxiii

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 entityxiv (please add additional rows as necessary)

X

Namexv

% 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

Standard Life Aberdeen plc

Aberdeen Asset Management PLC

Aberdeen Asset Investment Group Limited

Aberdeen Asset Investments Limited

Standard Life Aberdeen plc

Aberdeen Asset Management PLC

Aberdeen Asset Managers Limited

Standard Life Aberdeen plc

Aberdeen Asset Management PLC

Aberdeen Private Wealth Management Limited

Standard Life Aberdeen plc

Standard Life Investments (Holdings) Limited

Standard Life Investments Limited

7.66

0.00

7.66

Standard Life Aberdeen plc

Standard Life Investments (Holdings) Limited

Standard Life Wealth Limited

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 informationxvi

In reference to section 9, the shares detailed are managed by the named discretionary investment management entity within multiple portfolios on behalf of underlying clients, based on investment management agreements whereby the client has delegated the exercise of the voting power to the referenced investment manager.

In addition, this disclosure also highlights that the voting rights held indirectly by the underlying intermediate holding company, Standard Life Investments (Holdings) Limited, is above a notifiable threshold. As at the date detailed in Section 5, Standard Life Investments (Holdings) Limited effectively held the delegated voting rights to 7.73% of the shares in Phoenix Group Holdings.

Place of completion

Aberdeen, United Kingdom

Date of completion

12/07/2018