Chapter 11 ) VALARIS PLC, Et Al.,1 ) Case No

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IN THE UNITED STATES BANKRUPTCY COURT SOUTHERN DISTRICT OF TEXAS HOUSTON DIVISION

) In re: ) Chapter 11 ) VALARIS PLC, et al.,1 ) Case No. 20-34114 (MI) ) Debtors. ) (Jointly Administered) )

CERTIFICATE OF SERVICE

I, Ted Tokuda, depose and say that I am employed by Stretto, the claims and noticing agent for the Debtors in the above-captioned cases.

On January 8, 2021, at my direction and under my supervision, employees of Stretto caused 150 copies of the following document to be served via overnight mail on Mediant Communications Inc. at Attn: Stephany Hernandez, 100 Demarest Drive, Wayne, NJ 07470, Job # 1603664:

• Rights Offering Procedures (attached hereto as Exhibit A)

• Beneficial Holder Subscription Form (attached hereto as Exhibit B)

Furthermore, on January 8, 2021, at my direction and under my supervision, employees of Stretto caused 7,920 copies of the following document to be served via overnight mail on Broadridge Financial Services, Inc., at Attn: Receiving, 51 Mercedes Way, Edgewood, NY 11717, Job #s E22682, E22683, E22684, E22685, E22686:

• Rights Offering Procedures (attached hereto as Exhibit A)

• Beneficial Holder Subscription Form (attached hereto as Exhibit B)

______1 A complete list of each of the Debtors in these chapter 11 cases may be obtained on the website of the Debtors’ claims and noticing agent at https://www.cases.stretto.com/valaris. The location of Debtor Ensco Incorporated’s principal place of business and the Debtors’ service address in these chapter 11 cases is 5847 San Felipe Street, Suite 3300, Houston, Texas 77057. Case 20-34114 Document 947 Filed in TXSB on 01/12/21 Page 2 of 58

Furthermore, on January 8, 2021, at my direction and under my supervision, employees of Stretto caused the following document to be served via overnight mail on the service list attached hereto as Exhibit C, via first-class mail on the service list attached hereto as Exhibit D, and via electronic mail on the service list attached hereto as Exhibit E.

• Rights Offering Procedures (attached hereto as Exhibit A)

• Beneficial Holder Subscription Form (attached hereto as Exhibit B)

Dated: January 12, 2021 /s/ Ted Tokuda______Ted Tokuda STRETTO 410 Exchange, Suite 100 Irvine, CA 92602 (855) 348-2032 [email protected]

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Exhibit A

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VALARIS PLC, ET AL. (COLLECTIVELY, THE “DEBTORS” OR THE “COMPANY”) ON BEHALF OF AN ENTITY TO BE FORMED LATER (“NEW VALARIS HOLDCO”)

RIGHTS OFFERING PROCEDURES1

• Holders of Senior Notes Claims: To be able to exercise at least one Subscription Right, you must hold at least $1,000 principal amount of the Company’s 6.875% Senior Notes due 2020 (the “2020 Notes”), 7.875% Senior Notes due 2040 (the “2040 Notes” and, together with the 2020 Notes, the “Pride Notes”), 4.70% Senior Notes due 2021 (the “2021 Notes”), 8.00% Senior Notes due 2024 (the “8.00% 2024 Notes”), 4.50% Senior Notes due 2024 (the “4.50% 2024 Notes”), 5.20% Senior Notes due 2025 (the “5.20% 2025 Notes”), 7.75% Senior Notes due 2026 (the “2026 Notes”), 5.75% Senior Notes due 2044 (the “5.75% 2044 Notes” and, together with the 2021 Notes, the 8.0% 2024 Notes, the 4.50% 2024 Notes, the 5.20% 2025 Notes and the 2026 Notes, the “Valaris Notes”), 4.875% Senior Notes due 2022 (the “2022 Notes”), 4.75% Senior Notes due 2024 (the “4.75% 2024 Notes”), 7.375% Senior Notes due 2025 (the “7.375% 2025 Notes”), 5.40% Senior Notes due 2042 (the “2042 Notes”), 5.85% Senior Notes due 2044 (the “5.85% 2044 Notes” and, together with the 2022 Notes, the 4.75% 2024 Notes, the 7.375% 2025 Notes and the 2042 Notes, the “Legacy Rowan Notes”), 3.00% Exchangeable Senior Notes due 2024 (the “3.00% 2024 Notes” or the “Jersey Notes”) and/or 7.20% Debentures due 2027 (the “2027 Debentures” or the “Ensco International Debentures,” and, together with the Pride Notes, the Valaris Notes, the Legacy Rowan Notes and the Jersey Notes, the “Senior Notes”).

• Backstop Parties: Pursuant to the Backstop Agreement (as defined below), the Backstop Parties must exercise all their Subscription Rights issued pursuant to the Rights Offering (as defined below) and must purchase all the Rights Offering Securities (as defined below) issuable to them in relation thereto.

• If you exercise your Subscription Rights, you will have to PAY for such exercise at the Purchase Price, as described further below, and if applicable, arrange for the underlying Senior Notes to be submitted in accordance with the procedures described further below.

• Holders of Senior Notes Claims are not required to exercise any of their Subscription Rights (unless they are party to the Backstop Agreement), but they may if they wish to do so and they must follow the required procedures.

• Additional information is provided in this document and in the subscription form enclosed herewith.

1 Capitalized terms used and not defined herein shall have the meaning assigned to them in the Joint Chapter 11 Plan of Reorganization of Valaris plc, et al. (as may be amended, modified or supplemented in accordance with the terms thereof, the “Plan”) or the Backstop Commitment Agreement, dated as of August 18, 2020, by and among the Company and the other parties thereto, as amended.

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The New Secured Notes offered pursuant to the Rights Offering (the “Rights Offering Notes”) and New Valaris Equity consideration thereunder (the “Rights Offering Shares,” together with the Rights Offering Notes, the “Rights Offering Securities”) are being distributed and issued by the Company without registration under the Securities Act of 1933, as amended (the “Securities Act”), in reliance upon the exemption provided in Section 1145 of the Bankruptcy Code. None of the Subscription Rights or the Rights Offering Securities issuable upon exercise of such Subscription Rights have been or will be registered under the Securities Act or any state or local law requiring registration for offer and sale of a security.

The Subscription Rights will not be detachable or transferable separately from the Senior Notes. Rather, the Subscription Rights together with the applicable Senior Notes with respect to which such Subscription Rights were activated will trade together and be evidenced by the underlying Senior Notes until the Subscription Instruction Deadline, subject to such limitations, if any, that would be applicable to the transferability of the underlying Senior Notes; provided, that following the exercise of any Subscription Rights, the holder thereof shall be prohibited from transferring or assigning the Senior Notes corresponding to such Subscription Rights until the earlier of (i) termination of the Rights Offering and (ii) the revocation of exercise of such Subscription Rights to the extent permitted by these Rights Offering Procedures, provided further that any transfer or assignment mandated by the Confirmation Order or the Plan shall neither be prohibited nor impact the entitlement of any holder of any Senior Notes to any Subscription Rights validly exercised under these Rights Offering Procedures.

The Disclosure Statement (as defined below) has previously been distributed in connection with the Debtors’ solicitation of votes to accept or reject the Plan (as defined below) and that document sets forth important information, including risk factors, that should be carefully read and considered by each Eligible Holder (as defined below) prior to making a decision to participate in the Rights Offering. Additional copies of the Disclosure Statement are available upon request from Stretto (the “Subscription Agent”). The Disclosure Statement is also available on the case website at: https://cases.stretto.com/valaris/.

The Rights Offering is being conducted by the Company in good faith and in compliance with the Bankruptcy Code. In accordance with Section 1125(e) of the Bankruptcy Code, a debtor or any of its agents that participate, in good faith and in compliance with the applicable provisions of the Bankruptcy Code, in the offer, issuance, sale, or purchase of a security offered or sold under the plan of the debtor, of an affiliate participating in a joint plan with the debtor, or of a newly organized successor to the debtor under the plan, is not liable, on account of such participation, for violation of any applicable law, rule, or regulation governing the offer, issuance, sale or purchase of securities.

The distribution or communication of these Rights Offering Procedures and the issuance of the Rights Offering Securities in certain jurisdictions may be restricted by Law. No action has been taken or will be taken to permit the distribution or

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communication of these Rights Offering Procedures in any jurisdiction where any action for that purpose may be required. Accordingly, these Rights Offering Procedures may not be distributed or communicated, and the Rights Offering Securities may not be subscribed for or issued, in any jurisdiction except in circumstances where such distribution, communication, subscription or issuance would comply with all applicable Laws without the need for the Debtors to take any action or obtain any consent, approval or authorization therefor except for any notice filings required under U.S. federal and applicable state securities Laws. Further, the Company’s and/or New Valaris Holdco’s securities have not been approved or disapproved by the U.S. Securities and Exchange Commission or any other state securities commission or any other regulatory or governmental authority, nor have any of the foregoing passed upon the accuracy or adequacy of the information presented, and any representation to the contrary is a criminal offense.

These Rights Offering Procedures have been prepared on the basis that any offer of Rights Offering Securities or the Subscription Rights within any member state of the European Economic Area (the “EEA”) or in the United Kingdom (each a “Relevant State”) will be made pursuant to an exemption under Regulation (EU) 2017/1129 (the “Prospectus Regulation”) and/or the Financial Services and Markets Act 2000 (“FSMA”) (as applicable) from the requirement to publish a prospectus for the offer of transferable securities to the public. In relation to each Relevant State, no offer of the Rights Offering Securities or the Subscription Rights may be made to the public at any time other than pursuant to an exemption under the Prospectus Regulation and/or FSMA (as applicable). In any Relevant State, the Rights Offering and the Rights Offering Procedures are only addressed to and directed at: (i) “qualified investors” in that Relevant State within the meaning of the Prospectus Regulation or FSMA (as applicable) (“Qualified Investors”), (ii) not more than 149 natural or legal persons, other than Qualified Investors, per Relevant State or (iii) any other person if such address or direction does not otherwise constitute an offer of securities to the public within the meaning of the Prospectus Regulation (including in any of the other circumstances of Article 1(4) of the Prospectus Regulation) and/or FSMA (including in any of the other circumstances of section 86 of FSMA). None of the Company, New Valaris Holdco (as defined in the Plan), the Debtors or any of their respective affiliates or any persons acting on their behalves has authorized, nor do they authorize, the making of any offer of Rights Offering Securities or the Subscription Rights through any financial intermediary, other than as may be contemplated in the Rights Offering Procedures.

These Rights Offering Procedures should not be construed as an invitation or inducement to engage in any investment activity in relation to any Rights Offering Securities such as would amount to a financial promotion in the United Kingdom for the purposes of section 21 of FSMA. In the United Kingdom, the information contained in these Rights Offering Procedures is intended only for use and may only be relied upon in relation to any investment activity by, and any investment activity to which such information relates may only be engaged in by, persons falling within any of the circumstances of Article 1(4) of the Prospectus Regulation who are at the relevant time: (i) investment professionals within the meaning of Article 19(5) of the Financial Services

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and Markets Act 2000 (Financial Promotion) Order 2005 (“FPO”), (ii) high net worth companies within the meaning of Article 49(2)(a) to (d) of the FPO, (iii) persons that are existing members or creditors of the issuer of the Rights Offering Securities, or of an undertaking which at the relevant time is in the same group as the issuer of the Rights Offering Securities, falling within Article 43 of the FPO or (iv) persons to whom the communication may otherwise lawfully be communicated (together, the “Permitted UK Persons”). Any person in the United Kingdom that is not a Permitted UK Person is not, for the purposes of any investment or investment decision, an intended recipient of the information contained in these Rights Offering Procedures and should not use such information as the basis for taking any investment activity or investment action. These Rights Offering Procedures should not (insofar as they relate to any investment or investment activity) be distributed, communicated to, or directed at the general public in the United Kingdom otherwise than as described above.

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Eligible Holders should note the following times relating to the Rights Offering:

Date Calendar Date Event Senior Notes December 1, 2020 The date and time fixed by the Company for the Record Date determination of the Eligible Holders of Allowed Senior Note Claims who will receive these Rights Offering Procedures and the Registered Holder Subscription Form. However, persons that become Eligible Holders after December 1, 2020 may still participate in the Rights Offering by subscribing for Rights Offering Securities in accordance with these Rights Offering Procedures by the Subscription Instruction Deadline.

Subscription January 8, 2021 Commencement of the Rights Offering and the first Commencement date on which Eligible Holders may exercise Date Subscription Rights.

Subscription 5:00 p.m. New York The deadline for Eligible Holders to subscribe for Instruction time on February 3, Rights Offering Securities. An Eligible Holder’s Deadline 2021 Beneficial Holder Subscription Form (as defined below) and/or other instructions required by the Eligible Holder’s Nominee (as defined below) must be received by such Nominee in sufficient time to allow such Nominee to deliver the relevant Senior Notes through ATOP (as defined below) by the Subscription Instruction Deadline. Eligible Holders are urged to consult with their Nominee(s) to determine the necessary deadline to return their Beneficial Holder Subscription Forms to their Nominee. For the avoidance of doubt, the Subscription Agent may, in its discretion, permit nominees and/or depositories to provide certain Eligible Holder position verification information to the Subscription Agent on the next business day following the Subscription Instruction Deadline.

Subscription 5:00 p.m. New York Eligible Holders who are not Backstop Parties must Payment Deadline time on February 3, deliver the aggregate Purchase Price by the 2021 (other than for Subscription Instruction Deadline. Eligible Holders who are Backstop Parties) Eligible Holders who are Backstop Parties must arrange for the Backstop Party Addendum to be provided to their Nominee by the Subscription Instruction Deadline so that the Nominee will receive confirmation that payment does not have to be made prior to the Subscription Payment Deadline. Eligible Holders who are Backstop Parties shall not be

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required to pay their respective aggregate Purchase Price until required in accordance with the terms of the Backstop Agreement, as amended (referred to herein as the “Backstop Agreement”).

To Eligible Holders and Nominees of Eligible Holders:

On August 19, 2020, the Debtors filed voluntary petitions for relief with the United States Bankruptcy Court for the Southern District of Texas. On December 30, 2020 the Debtors filed the Third Amended Joint Chapter 11 Plan of Reorganization of Valaris plc, et al. (as may be amended, modified, or supplemented from time to time in accordance with the terms thereof, the “Plan”) and the Disclosure Statement Relating to the Debtors’ Third Amended Joint Chapter 11 Plan of Reorganization (as may be amended from time to time in accordance with its terms, the “Disclosure Statement”). The Disclosure Statement was approved by the Bankruptcy Court on December 30, 2020. Pursuant to the Plan each holder of Senior Notes Claims during the Rights Exercise Period (the “Eligible Holders”) shall be entitled to exercise Subscription Rights pursuant to the Rights Offering (as defined below), in each case, in accordance with the terms and conditions of these Rights Offering Procedures, provided that a holder of Senior Notes in a Relevant State shall only constitute an Eligible Holder (and be entitled to exercise Subscription Rights pursuant to these Rights Offering Procedures) if they are (i) a Qualified Investor or (ii) natural or legal persons (other than Qualified Investors) if the Company, in its discretion, determines that such persons constitute Eligible Holders subject to the Company’s obligation to ensure that no more than 149 natural or legal persons (other than Qualified Investors) in any Relevant State are offered or permitted to acquire Rights Offering Notes. The Rights Offering Notes are only offered to 149 natural or legal persons (other than Qualified Investors) in any Relevant State and participation in Rights Offering Notes is accordingly limited. The “Purchase Price” shall be $1,000.00 per Rights Offering Note.

Senior Notes: Pursuant to the Plan, Eligible Holders, including the Backstop Parties, will have the right (but not the obligation, except in the case of Eligible Holders who are Backstop Parties) to subscribe for up to $312.5 million of Rights Offering Notes and each Eligible Holder’s pro rata portion (in respect of the Subscription Rights exercised by such Eligible Holder) of 18.75%2 of the New Valaris Equity (the “Rights Offering”), as applicable. In accordance with the terms of the Backstop Agreement, the Backstop Parties shall have the right and obligation to subscribe for $187.5 million of the New Secured Notes and each Backstop Party’s pro rata portion (in respect of such Backstop Party’s allocation of such $187.5 million of New Secured Notes) of 11.25%3 of the New Valaris Equity and shall fully backstop the remainder of the Rights Offering.

Unless otherwise directed by the relevant depository, beneficial holders should return their subscription forms (each a “Beneficial Holder Subscription Form”) only to the broker, bank, commercial bank, transfer agent, trust company, dealer, or other agent or nominee (as applicable, the “Nominee”) for processing.

As part of the exercise process, following exercise of Subscription Rights, the related Senior Notes held through DTC will be frozen from trading, as described below. All Beneficial Holder

2 For the avoidance of doubt, equity distributed under the Plan is subject to dilution by, if relevant, the New Warrants, the Newbuild Equity Pool, and the Management Incentive Plan, in accordance with the Plan. 3 For the avoidance of doubt, equity distributed under the Plan is subject to dilution by, if relevant, the New Warrants, the Newbuild Equity Pool, and the Management Incentive Plan, in accordance with the Plan. 6

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Subscription Forms and/or other instructions required by the Nominee must be returned to the applicable Nominee in sufficient time to allow such Nominee to process and deliver the underlying Senior Notes through The Depository Trust Company (“DTC”) Automated Tender Offer Program (“ATOP”). By instructing its Nominee to submit underlying Senior Notes through ATOP, the holder is (i) authorizing its Nominee to exercise all Subscription Rights associated with the amount of Senior Notes as to which the instruction pertains; and (ii) certifying that it understands that, once submitted, the underlying Senior Notes will be frozen from trading until the Effective Date, at which point or as soon as reasonably practicable thereafter (a) the underlying Senior Notes will be cancelled pursuant to the Plan; (b) the holder will receive its distribution pursuant to the Plan; and (c) the holder will receive its applicable Rights Offering Securities. The amount of time necessary for a Nominee to process and deliver the applicable Senior Notes through ATOP may vary. Holders are urged to consult with their Nominees to determine the necessary deadline to return their Beneficial Holder Subscription Forms to their Nominee. Failure to submit such Beneficial Holder Subscription Form (or other instructions required by the Nominee) on a timely basis, as applicable, may result in forfeiture of an Eligible Holder’s Subscription Rights. None of the Company, New Valaris Holdco (as defined in the Plan), any of their Subsidiaries, the Subscription Agent or any of the Backstop Parties (except such Eligible Holder, if applicable) will have any liability for any such failure.

No Eligible Holder (except a Backstop Party) shall be entitled to participate in the Rights Offering unless the Purchase Price for the Rights Offering Securities it subscribes for is received by the Subscription Agent by the Subscription Payment Deadline. For all Eligible Holders (except Backstop Parties), payment of the Purchase Price must be made at the same time it returns its Beneficial Holder Subscription Form to its Nominee, but in no event later than the Subscription Instruction Deadline. Backstop Parties are party to the Backstop Agreement, have already been designated, and are known both to the Company and to themselves.

Special note for Backstop Parties. Backstop Parties will receive (through their counsel, if applicable, or other appropriate means) an addendum (the “Backstop Party Addendum”), and must arrange for the Backstop Party Addendum to be provided to their Nominee so that the Nominee will receive confirmation that payment does not have to be made prior to the Subscription Payment Deadline. An Eligible Holder that is a Backstop Party must provide its payment in accordance with Section 2.4 of the Backstop Agreement.

The rights and obligations of the Backstop Parties in the Rights Offering shall be governed by the Backstop Agreement to the extent the rights or obligations set forth therein differ from the rights and obligations set forth in these Rights Offering Procedures or any Beneficial Holder Subscription Form or Registered Holder Subscription Form.

No interest is payable on any advanced funding of the Purchase Price. If the Rights Offering is terminated for any reason, the aggregate Purchase Price previously received by the Subscription Agent will be returned to Eligible Holders as provided in Section 6 hereof. No interest will be paid on any returned Purchase Price.

To participate in the Rights Offering, an Eligible Holder must complete all of the steps outlined below. If an Eligible Holder does not complete all of the steps outlined below by the Subscription Instruction Deadline or (if not a Backstop Party) Subscription Payment Deadline, as applicable, such Eligible Holder shall be deemed to have forever and irrevocably relinquished and waived its right to participate in the Rights Offering.

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1. Rights Offering

Eligible Holders have the right, but not the obligation, to participate in the Rights Offering; provided, however, that Eligible Holders that are Backstop Parties must exercise their Subscription Rights pursuant to the Backstop Agreement.

Subject to the terms and conditions set forth in the Plan and these Rights Offering Procedures, each Eligible Holder, including each Backstop Party, during the Rights Exercise Period is entitled to subscribe for up to its respective pro rata share, of the applicable percentage of Rights Offering Securities (determined as a percentage of the Senior Notes Distributable Pool (as defined in the Plan) and based on applicable Allowed Senior Notes Claim amount) and, in each case, at the Purchase Price.

The difference in the number of Rights Offering Securities that an Eligible Holder is entitled to subscribe for with respect to each series of Senior Notes takes into account the differing amounts, which reflects the current claim amount(s) as of the Subscription Commencement Date, of prepetition accrued and unpaid interest thereon. For the avoidance of doubt, Eligible Holders should use their principal amount when calculating their Rights Offering Securities on the applicable Subscription Form.

There will be no over-subscription privileges in the Rights Offering. Any remaining Rights Offering Securities will not be offered to other Eligible Holders but will be purchased by the applicable Backstop Parties in accordance with the Backstop Agreement. Subject to the terms and conditions of the Backstop Agreement, each Backstop Party is obligated to exercise all applicable Subscription Rights that are held by it as of the expiration of the Rights Offering and to purchase its pro rata portion of the applicable Rights Offering Securities not subscribed for by other Eligible Holders.

Any Eligible Holder that subscribes for Rights Offering Securities and is deemed to be an “underwriter” under Section 1145(b) of the Bankruptcy Code will be subject to restrictions under the Securities Act on its ability to resell those securities. Resale restrictions are discussed in more detail in Article XI of the Disclosure Statement, entitled “Certain Securities Law Matters.”

SUBJECT TO THE TERMS AND CONDITIONS OF THE RIGHTS OFFERING PROCEDURES (AND THE BACKSTOP AGREEMENT IN THE CASE OF ANY BACKSTOP PARTY), ALL SUBSCRIPTIONS SET FORTH IN THE BENEFICIAL HOLDER SUBSCRIPTION FORM ARE IRREVOCABLE.

2. Rights Exercise Period

The Rights Offering will commence and the Subscription Rights will be activated on the Subscription Commencement Date and will expire at the Subscription Instruction Deadline. Each Eligible Holder intending to purchase Rights Offering Securities in the Rights Offering must affirmatively elect to exercise its Subscription Rights in the manner set forth in the applicable Subscription Form by the Subscription Instruction Deadline (except for Eligible Holders that are Backstop Parties) and must pay for any exercised Subscription Rights by the applicable deadline.

Any exercise (including payment) of Subscription Rights by an Eligible Holder (other than a Backstop Party) after the Subscription Instruction Deadline will not be allowed and any purported exercise (including payment) received by the Subscription Agent after the Subscription Instruction Deadline, 8

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regardless of when the documents or payment relating to such exercise were sent, will not be honored. Any unexercised Subscription Rights shall be irrevocably waived.

Although Backstop Parties are not required to pay the Purchase Price at or prior to the Subscription Payment Deadline, if any Backstop Parties hold Senior Notes Claims they are required to deliver a Subscription Form and Backstop Party Addendum to their Nominee so that the Nominee will receive confirmation that payment does not have to be made prior to the Subscription Payment Deadline when tendering the underlying Senior Notes through ATOP.

The Subscription Instruction Deadline may be extended by the Company in its reasonable discretion with the prior written approval of the Requisite Backstop Parties, which approval may not be unreasonably withheld, delayed or conditioned, or as required by law.

3. Delivery of Subscription Documents

Each Eligible Holder may exercise all or any portion of such Eligible Holder’s Subscription Rights, but subject to the terms and conditions contained herein. In order to facilitate the exercise of the Subscription Rights, beginning on the Subscription Commencement Date, the applicable Subscription Form and these Rights Offering Procedures will be sent to Eligible Holders at that time, together with appropriate instructions for the proper completion, due execution and timely delivery of the executed Subscription Form and the payment of the applicable aggregate Purchase Price for its Rights Offering Securities.

4. Exercise of Subscription Rights

For any Eligible Holder holding through a Nominee: In order to exercise an Eligible Holder’s Subscription Rights, such Eligible Holder’s Nominee must submit the relevant portion of Senior Notes as to which the Subscription Rights pertain into the ATOP system to the account maintained by the Subscription Agent with DTC. (For any Eligible Holder holding Senior Notes as a record holder in its own name please follow the steps outlined in the Registered Holder Subscription Form that should have been mailed to you.)

(a) In order to validly exercise its Subscription Rights, each Eligible Holder that is not a Backstop Party must:

i. return duly completed and executed its Beneficial Holder Subscription Form (with an accompanying IRS Form W-9 or appropriate IRS Form W-8, as applicable) to its Nominee (or otherwise follow the directions of its Nominee), so that such holder’s subscription instructions may be effected by the Nominee by delivering the applicable Senior Notes via DTC’s ATOP system prior to the Subscription Instruction Deadline; and

ii. at the same time it returns its Beneficial Holder Subscription Form to its Nominee, but in no event later than the Subscription Instruction Deadline, pay, or arrange for the payment by its Nominee of, the applicable Purchase Price to the Subscription Agent by wire transfer ONLY of immediately available funds in accordance with the instructions included in the Beneficial Holder Subscription Form.

(b) In order to validly exercise its Subscription Rights, each Eligible Holder that is a Backstop Party must: 9

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i. return its duly completed and executed Beneficial Holder Subscription Form to its Nominee (or otherwise follow the directions of its Nominee), so that such holder’s subscription instructions may be effected by the Nominee by delivering the applicable Senior Notes via DTC’s ATOP system prior to the Subscription Instruction Deadline;

ii. ensure that the Backstop Party Addendum is provided to their Nominee so that the Nominee will receive confirmation that payment does not have to be made prior to the Subscription Payment Deadline and will have the relevant information to enter into the ATOP system; and iii. no later than as required by the terms of the Backstop Agreement and Plan, pay such amounts, if any, required to be paid by such Backstop Party to the Backstop Escrow Account.

ALL BACKSTOP PARTIES MUST MAKE PAYMENTS TO THE BACKSTOP ESCROW ACCOUNT, AND SHOULD NOT PAY THEIR NOMINEE(S).

(c) With respect to 4(a) and (b) above, each Eligible Holder must duly complete, execute and return its Beneficial Holder Subscription Form to its Nominee (or otherwise follow its Nominee’s instructions) in sufficient time to allow its Nominee to process its instructions and deliver the underlying Senior Notes through ATOP, and, solely with respect to the Eligible Holders that are not Backstop Parties, payment of the applicable Purchase Price for the Rights Offering Securities elected to be purchased by such Eligible Holder by the Subscription Payment Deadline. Eligible Holders that are Backstop Parties must deliver payments in connection with the Rights Offering to the Backstop Escrow Account in accordance with the terms of the Backstop Agreement.

(d) In the event that the funds received by the Subscription Agent, as applicable, from any Eligible Holder (other than a Backstop Party) do not correspond to the Purchase Price payable for the Rights Offering Securities elected to be purchased by such Eligible Holder, the number of the Rights Offering Securities deemed to be purchased by such Eligible Holder will be the lesser of (a) the number of the Rights Offering Securities elected to be purchased by such Eligible Holder as evidenced by the relevant ATOP submission(s) and (b) a number of the Rights Offering Securities determined by dividing the amount of the funds received by the Purchase Price, in each case up to such Eligible Holder’s pro rata portion of Rights Offering Securities.

(e) Other than with respect to the Backstop Parties, the cash paid to the Subscription Agent in accordance with these Rights Offering Procedures will be deposited and held by the Subscription Agent in a segregated account until released to the Debtors in connection with the settlement of the Rights Offering on or around the Effective Date. The Subscription Agent may not use such cash for any other purpose prior to the Effective Date and may not encumber or permit such cash to be encumbered with any lien or similar encumbrance. The cash held by the Subscription Agent hereunder (or in the Subscription Account) shall not be deemed part of the Debtors’ bankruptcy estates.

5. Transfer Restriction; Revocation

(a) The Subscription Rights will not be detachable or transferable separately from the Senior Notes. If any Subscription Rights are transferred by an Eligible Holder in contravention 10

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of the foregoing, the Subscription Rights will be cancelled, and neither such Eligible Holder nor the purported transferee will receive any Rights Offering Securities otherwise purchasable on account of such transferred Subscription Rights;

(b) The Subscription Rights together with the underlying Senior Notes with respect to which such Subscription Rights were activated, will trade together as a unit, subject to such limitations, if any, that would be applicable to the transferability of the underlying Senior Notes; and

(c) Once an Eligible Holder has properly exercised its Subscription Rights, subject to the terms and conditions contained in these Rights Offering Procedures and the Backstop Agreement in the case of any Backstop Party, such exercise will be irrevocable. Moreover, following the exercise of any Subscription Rights, the holder thereof shall be prohibited from transferring or assigning the Senior Notes corresponding to such Subscription Rights until the earlier of (i) termination of the Rights Offering and (ii) the revocation of exercise of the Subscription Rights to the extent permitted by these Rights Offering Procedures, provided that any transfer or assignment mandated by the Confirmation Order or the Plan shall neither be prohibited nor impact the entitlement of any holder of any Senior Notes or Subscription Rights validly exercised under these Rights Offering Procedures.

6. Termination/Return of Payment

Unless the Effective Date has occurred, the Rights Offering will be deemed automatically terminated without any action of any party upon the earliest of (i) termination of the Restructuring Support Agreement in accordance with its terms, (ii) termination of the Backstop Agreement in accordance with its terms, (iii) the Debtors’ revocation or withdrawal of the Plan and (iv) the Outside Date (as such date is defined in and may be extended pursuant to the terms of the Backstop Agreement). In the event the Rights Offering is terminated, any payments received pursuant to these Rights Offering Procedures will be returned, without interest, to the applicable Eligible Holder as soon as reasonably practicable, but in any event within three business days after the date of termination, and, in the case of payments made in respect of Senior Notes held through a Nominee, the underlying Senior Notes will be returned to the Nominee that submitted them through ATOP.

7. Settlement of the Rights Offering and Distribution of the Rights Offering Securities

The settlement of the Rights Offering is conditioned on confirmation of the Plan by the Bankruptcy Court, compliance by the Debtors with these Rights Offering Procedures, and the simultaneous occurrence of the Effective Date. The Debtors intend that the Rights Offering Securities will be issued to the Eligible Holders in book-entry form, and that DTC, or its nominee, will be the holder of record of such Rights Offering Securities for any Rights Offering Securities exercised through a Nominee or those registered holders who wish to hold their Rights Offering Securities at a nominee. To the extent DTC is unwilling or unable to make the Rights Offering Securities eligible on the DTC system, the Rights Offering Securities will be issued directly to the Eligible Holders on the books and records of the transfer agent and the indenture trustee.

8. Fractional Shares

No fractional Rights Offering Securities will be issued in the Rights Offering. All share allocations

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(including each Eligible Holder’s Rights Offering Shares) will be calculated and rounded down to the nearest whole share. All principal amount of Rights Offering Note allocations shall be rounded to the nearest minimum denomination of $1.00 and integral multiples of $1.00 in excess thereof. The total amount of Rights Offering Securities that may be purchased pursuant to the Rights Offering shall be adjusted as necessary to account for the rounding described in this Section 8. No compensation shall be paid, whether in cash or otherwise, in respect of any rounded-down amounts.

9. Validity of Exercise of Subscription Rights

All questions concerning the timeliness, viability, form and eligibility of any exercise of Subscription Rights will be determined in good faith by the Debtors in consultation with the Requisite Backstop Parties, and, if necessary, subject to a final and binding determination by the Bankruptcy Court. Subject to the foregoing, the Debtors, with the consent of the Requisite Backstop Parties, may waive or reject any defect or irregularity in, or permit such defect or irregularity to be corrected within such time as they may determine in good faith, the purported exercise of any Subscription Rights. Subscriptions will be deemed not to have been received or accepted until all irregularities have been waived or cured within such time as the Debtors determine in good faith in consultation with the Requisite Backstop Parties. In addition, the Subscription Agent shall have no obligation to notify parties of or cure any defects to the forms returned in exercising the Subscription Rights.

Before exercising any Subscription Rights, Eligible Holders should read the Disclosure Statement and the Plan for information relating to the Debtors and the risk factors to be considered.

All calculations shall be made in good faith by the Company with the consent of the Requisite Backstop Parties, which consent may not be unreasonably withheld, delayed or conditioned, and in accordance with any claim amounts included in the Plan, and any disputes regarding such calculations shall be subject to a final and binding determination by the Bankruptcy Court.

10. Modification of Procedures

With the prior written consent of the Requisite Backstop Parties, the Debtors reserve the right to modify these Rights Offering Procedures, or adopt additional procedures consistent with these Rights Offering Procedures to effectuate the Rights Offering and to issue the Rights Offering Securities, provided, however, that the Debtors shall provide prompt written notice to each Eligible Holder of any material modification to these Rights Offering Procedures made after the Subscription Commencement Date by posting a notice with respect to the modified or additional procedures on the Debtors’ case website, provided further that any amendments or modifications to the terms of the Rights Offering are subject to the provisions of Section 6.1 of the Backstop Agreement. In so doing, and subject to the consent of the Requisite Backstop Parties, which consent may not be unreasonably withheld, delayed or conditioned, the Debtors may execute and enter into agreements and take further action that the Debtors determine in good faith is necessary and appropriate to effectuate and implement the Rights Offering and the issuance of the Rights Offering Securities.

The Debtors reserve the right to request additional information from any participant in the Rights Offering to confirm that such participant is an Eligible Holder.

11. DTC

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Some or all of the Senior Notes are held in book-entry form in accordance with the practices and procedures of DTC. The Debtors intend to comply with the practices and procedures of DTC for the purpose of conducting the Rights Offering, and, subject to compliance with Section 10 hereof, these Rights Offering Procedures will be deemed appropriately modified to achieve such compliance.

Without limiting the foregoing the Company intends that, to the extent practicable, the Rights Offering Securities will be issued in book-entry form and that DTC, or its nominee, will be the holder of record of such Rights Offering Securities for any Rights Offering Securities exercised through a Nominee. The ownership interest of each holder of such Rights Offering Securities, and transfers of ownership interests therein, is expected to be recorded on the records of the direct and indirect participants in DTC. It is expected that all exercised Rights Offering Securities will be automatically allocated to exercising holders through DTC on or as soon as practicable after the Effective Date.

12. Inquiries and Transmittal of Documents; Subscription Agent

The Rights Offering Instructions for Eligible Holders attached hereto should be carefully read and strictly followed by the Eligible Holders.

Questions relating to the Rights Offering should be directed to the Subscription Agent via email to [email protected] (please reference “Valaris Rights Offering” in the subject line) or at the following phone number: (855) 586-3872 (domestic toll-free) or (949) 325-6215 (international). Please note that the Subscription Agent is only able to respond to procedural questions regarding the Rights Offering, and cannot provide any information beyond that included in these Rights Offering Procedures and the Beneficial Holder Subscription Forms or Registered Holder Subscription Forms, as applicable. An Eligible Holder must follow the directions of its Nominee with respect to providing instructions to it in connection with the Rights Offering.

The risk of non-delivery of any instructions, documents, and payments to any Nominee or to the Subscription Agent or the Rights Offering Escrow Accounts is on the Eligible Holder electing to exercise its Subscription Rights and not the Debtors, New Valaris Holdco, any of their Subsidiaries, the Subscription Agent, or the Backstop Parties.

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VALARIS PLC, ET AL. (COLLECTIVELY, THE “DEBTORS” OR THE “COMPANY”) ON BEHALF OF AN ENTITY TO BE FORMED LATER

RIGHTS OFFERING INSTRUCTIONS FOR ELIGIBLE HOLDERS

Capitalized terms used and not defined herein shall have the meaning assigned to them in the Plan.

To elect to participate in the Rights Offering, you must follow the instructions set out below:

1. Insert the principal amount of the Company’s Pride Notes, Valaris Notes, Legacy Rowan Notes, Jersey Notes and/or Ensco International Debentures, as applicable, that you hold in Item 1 of your Beneficial Holder Subscription Form (if you do not know such amount, please contact your Nominee immediately).

2. Complete the worksheet in Item 2 of your Beneficial Holder Subscription Form, which calculates the maximum number of Rights Offering Notes available for you to purchase. Such amount must be rounded to the nearest whole number.

3. Complete Item 3 of your Beneficial Holder Subscription Form to indicate the number of Rights Offering Securities you elect to purchase and the aggregate Purchase Price for such Rights Offering Securities. IMPORTANT: If you do not wish to purchase all of the Rights Offering Securities to which you are entitled, you must provide instructions to your Nominee to ONLY submit the relevant portion of Senior Notes into the ATOP system. For example, if you only wish to subscribe for 50% of your Senior Notes, then request that your Nominee submit only 50% of your Senior Notes through ATOP.

4. Read, complete and sign the certification in Item 5 of your Beneficial Holder Subscription Form. Such execution shall indicate your acceptance and approval of the terms and conditions set forth in these Rights Offering Procedures.

5. Read and complete the certification in Item 7 of your Beneficial Holder Subscription Form certifying that, if in a Relevant State, you are a Qualified Investor or, if not a Qualified Investor, specifying your Relevant State.

6. Complete Item 9 (Registration Information) of your Beneficial Holder Subscription Form to indicate the registration information the Rights Offering Securities should be issued in the event the Rights Offering Securities are not DTC eligible.

7. Return your signed Beneficial Holder Subscription Form to your Nominee, or otherwise follow your Nominee’s instructions with respect to the Rights Offering, in sufficient time to allow your Nominee to process your instructions and deliver your underlying Senior Notes through ATOP by the Subscription Instruction Deadline in a manner consistent with these Rights Offering Procedures and the Backstop Agreement.

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8. Arrange for full payment of the aggregate Purchase Price by wire transfer of immediately available funds, calculated in accordance with Item 3 of your Beneficial Holder Subscription Form. For any Eligible Holders that are not Backstop Parties, please instruct your Nominee to coordinate payment of the Purchase Price and transmit and deliver such payment to the Subscription Agent by the Subscription Payment Deadline. Any Backstop Party should follow the payment instructions that will be provided in the applicable Funding Notice, taking into account, in the case of Backstop Parties that are also lenders under the DIP Facility, the net amount due to/from such Backstop Party after giving effect to amounts outstanding under the DIP Facility. Please contact Stretto at (Domestic) 855- 586-3872 or (International) 949-325-6215 for WIRE verification.

9. For Backstop Parties ONLY, confirm that you are a Backstop Party by providing the Backstop Party Addendum to your Nominee, so that the Nominee will (i) receive confirmation that payment does not have to be made prior to the Subscription Payment Deadline and (ii) have the relevant information to enter into the ATOP system. (This instruction is only for Backstop Parties, each of which is aware of their status as a Backstop Party).

 The Subscription Instruction Deadline shall be 5:00 p.m. Eastern Time on February 3, 2021.

 The Subscription Payment Deadline, for Eligible Holders that are not Backstop Parties, shall be 5:00 p.m. Eastern Time on the Subscription Instruction Deadline.

Please note that the Beneficial Holder Subscription Form (and/or other instructions required by your Nominee) must be received by your Nominee in sufficient time to allow such Nominee to process and deliver the applicable Senior Notes through ATOP by the Subscription Instruction Deadline, along with the appropriate funding (with respect to Eligible Holders that are not Backstop Parties) or the subscription represented by your Beneficial Holder Subscription Form will not be counted and you will be deemed forever to have relinquished and waived your right to participate in the Rights Offering.

Eligible Holders that are Backstop Parties must deliver the appropriate funding (if any) to the Backstop Escrow Account in accordance with the terms of the Backstop Agreement.

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QUESTIONS AND ANSWERS ABOUT THE VALARIS RIGHTS OFFERING

The following questions and answers are a summary of the Rights Offering Procedures and related documents, which govern the terms of the Rights Offering.

The Disclosure Statement has previously been distributed in connection with the Debtors’ solicitation of votes to accept or reject the Plan and that document sets forth important information, including risk factors, that should be carefully read and considered by each Eligible Holder prior to making a decision to participate in the Rights Offering.

Q: Why did I receive information about the Rights Offering?

A: You received information about the Rights Offering because you were a Holder of Senior Notes Claims as of the Senior Notes Record Date and may be eligible to participate in the Rights Offering.

Q: Who is eligible to participate in the Rights Offering?

A: All Eligible Holders of Senior Notes Claims during the Rights Exercise Period. Eligible Holders does not include persons or entities (other than Qualified Investors) that are residents of, or located in, any member state of the EEA or the United Kingdom (each a “Relevant State”), in excess of 149 natural or legal persons in any Relevant State and participation in Rights Offering Notes is accordingly limited. This means that Eligible Holders that are persons or entities that are residents of, or located in, a Relevant State must be Qualified Investors or natural or legal persons (other than Qualified Investors) with respect to which the Company, in its discretion, determines that such persons or entities constitute Eligible Holders. Such determination is subject to no more than 149 natural or legal persons (other than Qualified Investors) in any Relevant State being offered or permitted to acquire Rights Offering Notes.

“Qualified Investor” has the meaning ascribed to it in the Prospectus Regulation and includes (in summary) a person that is (i) an entity required to be authorized or regulated to operate in financial markets, such as (among others) an investment firm or a credit institution; (ii) a large undertaking meeting the requisite quantitative thresholds; (iii) a national or regional government, a public body that manages public debt, a central bank or an international or supranational institution; (iv) any other institutional investor whose main activity is to invest in financial instruments; or (v) a person or entity who does not fall within any of the descriptions at (i) to (iv) above but who is, on request, treated as a “professional client” in accordance with Section II of Annex II to Directive 2014/65/EU.

If you are located in any Relevant State, you should refer to the Rights Offering Procedures for additional details, and contact your own legal counsel, to determine whether you are eligible to participate in the Rights Offering.

Q: What is the record date for the mailing of the Rights Offering Procedures and the Registered Holder Subscription Form?

A: The Company has fixed December 1, 2020 as the record date for the determination of the Eligible Holders to receive the mailing of these Rights Offering Procedures and the Registered Holder Subscription Form. However, persons that become Eligible Holders after December 1, 2020 may still participate in the Rights Offering by subscribing for Rights Offering Securities in accordance with these Rights Offering Procedures by the Subscription Instruction Deadline.

Q: When do the Subscription Rights expire?

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A: The Rights Offering will commence and the Subscription Rights will be activated on the Subscription Commencement Date and will expire at the Subscription Instruction Deadline. Each Eligible Holder intending to purchase Rights Offering Securities in the Rights Offering must affirmatively elect to exercise its Subscription Rights in the manner set forth in the applicable Subscription Form by the Subscription Instruction Deadline and must pay for any exercised Subscription Rights by the applicable deadline (except for Eligible Holders that are Backstop Parties).

Q: What is a Subscription Right?

A: “Subscription Rights” means the rights provided to Eligible Holders of Senior Notes Claims to participate in the Rights Offering.

Q: What is being offered pursuant to the Rights Offering?

Eligible Holders of the Subscription Rights, including the Backstop Parties, will receive the opportunity to subscribe for up to $312.5 million of the New Secured Notes in accordance with and pursuant to the Plan, the Rights Offering Procedures, and the New Secured Notes Term Sheet. Each holder of Subscription Rights (including the Backstop Parties) that participates in the Rights Offering shall also receive, in consideration for its participation in the Rights Offering, its pro rata share (in respect of the Subscription Rights exercised by such Holder) of 18.75 percent of the issued and outstanding New Valaris Equity as of the Effective Date (subject to dilution by the Newbuild Equity Pool, New Warrants and the Management Incentive Plan).

Q: What happens if the Rights Offering is not fully subscribed?

A: If the Rights Offering is not fully subscribed, the Backstop Parties shall fully backstop the unsubscribed portion of the Rights Offering in accordance with the Backstop Agreement.

Q: May I sell or otherwise transfer my Subscription Rights if I do not want to participate in the Rights Offering?

A: The Subscription Rights will not be detachable or transferable separately from the Senior Notes. Rather, the Subscription Rights together with the applicable Senior Notes with respect to which such Subscription Rights were activated will trade together and be evidenced by the underlying Senior Notes until the Subscription Instruction Deadline, subject to such limitations, if any, that would be applicable to the transferability of the underlying Senior Notes; provided, that following the exercise of any Subscription Rights, the holder thereof shall be prohibited from transferring or assigning the Senior Notes corresponding to such Subscription Rights until the earlier of (i) termination of the Rights Offering and (ii) the revocation of exercise of such Subscription Rights to the extent permitted by these Rights Offering Procedures.

Q: Do I have to exercise my Subscription Rights in full?

A: No. Unless you are a Backstop Party, each Eligible Holder may exercise all or any portion of such Eligible Holder’s Subscription Rights, but subject to the terms and conditions contained herein and in the Beneficial Holder Subscription Form.

Q: How do I exercise my Subscription Rights?

A: To participate in the Rights Offering, an Eligible Holder must complete all of the applicable steps outlined within these Rights Offering Procedures and the Beneficial Holder Subscription Form. If an

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Eligible Holder does not complete all of the applicable steps outlined herein by the Subscription Instruction Deadline or (if not a Backstop Party) Subscription Payment Deadline, as applicable, such Eligible Holder shall be deemed to have forever and irrevocably relinquished and waived its right to participate in the Rights Offering.

Q: When will I receive the Rights Offering Securities?

A: The settlement of the Rights Offering is conditioned on confirmation of the Plan by the Bankruptcy Court, compliance by the Debtors with these Rights Offering Procedures, and the simultaneous occurrence of the Effective Date. The Debtors intend that the Rights Offering Securities will be issued to the Eligible Holders in book-entry form, and that DTC, or its nominee, will be the holder of record of such Rights Offering Securities for any Rights Offering Securities exercised through a Nominee or those registered holders who wish to hold their Rights Offering Securities at a nominee. To the extent DTC is unwilling or unable to make the Rights Offering Securities eligible on the DTC system, the Rights Offering Securities will be issued directly to the Eligible Holders on the books and records of the transfer agent and/or the indenture trustee, as applicable.

Q: If I exercise my Subscription Rights in the Rights Offering, may I withdraw the exercise?

A: Exercised Subscription Rights may only be withdrawn before the Subscription Instruction Deadline.

Q: May I subscribe for more than my pro rata share of the Rights Offering Securities?

A: No. There will be no over-subscription privilege in the Rights Offering.

Q: Can Nominees submit bulk ATOP instructions?

A: No, Nominees must tender Eligible Holders’ Senior Notes on a per holder basis. Nominees may not submit bulk tender instructions.

Q: If the Rights Offering is not consummated, will my payment be refunded to me?

A: Yes. Unless the Effective Date has occurred, the Rights Offering will be deemed automatically terminated without any action of any party upon the earliest of (i) termination of the Restructuring Support Agreement in accordance with its terms, (ii) termination of the Backstop Agreement in accordance with its terms, (iii) the Debtors’ revocation or withdrawal of the Plan and (iv) the Outside Date (as such date is defined in and may be extended pursuant to the terms of the Backstop Agreement). In the event the Rights Offering is terminated, any payments received pursuant to these Rights Offering Procedures will be returned, without interest, to the applicable Eligible Holder as soon as reasonably practicable, but in any event within three business days after the date of termination, and, in the case of payments made in respect of Senior Notes held through a Nominee, the underlying Senior Notes will be returned to the Nominee that submitted them through ATOP.

Q: What should I do if I have other questions?

A: If you have any questions about, or require assistance regarding, the procedure for exercising your Subscription Rights, please contact Stretto at:

Valaris plc, et al., Rights Offering. c/o Stretto 410 Exchange, Suite 100

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Irvine, California 92602 855-586-3872 (Domestic) or 949-325-6215 (International) [email protected]

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Exhibit B

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VALARIS PLC, ET AL. ON BEHALF OF AN ENTITY TO BE FORMED LATER

BENEFICIAL HOLDER SUBSCRIPTION FORM FOR RIGHTS OFFERING

FOR USE BY ELIGIBLE HOLDERS OF SENIOR NOTES

IN CONNECTION WITH DEBTORS’ DISCLOSURE STATEMENT DATED DECEMBER 30, 2020

SUBSCRIPTION INSTRUCTION DEADLINE

AND

SUBSCRIPTION PAYMENT DEADLINE

The Subscription Instruction Deadline is 5:00 p.m. Eastern Time on February 3, 2020.

The Subscription Payment Deadline (other than for Backstop Parties) is 5:00 p.m. Eastern Time on February 3, 2020.

Please note that your Beneficial Holder Subscription Form (or other form of instruction required by your Nominee) must be received by your Nominee in sufficient time to allow such Nominee to deliver your underlying Senior Notes through ATOP by the Subscription Instruction Deadline or your subscription will not be counted and will be deemed forever relinquished and waived and payment of the Aggregate Purchase Price (as defined below) must be made by the Subscription Payment Deadline (except with respect to Backstop Parties). Please note that you are responsible for all calculations made pursuant to this Beneficial Holder Subscription Form.

Eligible Holders who are Backstop Parties must arrange for the Backstop Party Addendum to be provided to their Nominee so that the Nominee will receive confirmation that payment does not have to be made prior to the Subscription Payment Deadline. Eligible Holders who are Backstop Parties shall not be required to pay their respective Aggregate Purchase Price until such Purchase Price payment is required in accordance with the terms of the Backstop Agreement, as amended.

The Rights Offering Securities are being distributed and issued by the Debtors without registration under the Securities Act of 1933, as amended (the “Securities Act”), in reliance upon the exemption provided in section 1145 of the Bankruptcy Code.

None of the Rights Offering Securities have been registered under the Securities Act, nor any State or local law requiring registration for offer or sale of a security.

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Neither the Rights Offering Procedures nor the Beneficial Holder Subscription Form should be construed as an invitation or inducement to engage in any investment activity in relation to any Rights Offering Securities such as would amount to a financial promotion in the United Kingdom for the purposes of section 21 of FSMA. In the United Kingdom, the information contained in the Rights Offering Procedures and the Beneficial Holder Subscription Form is intended only for use and may only be relied upon in relation to any investment activity by, and any investment activity to which such information relates may only be engaged in by, persons falling within any of the circumstances of Article 1(4) of the Prospectus Regulation who are at the relevant time: (i) investment professionals within the meaning of Article 19(5) of the Financial Services and Markets Act 2000 (Financial Promotion) Order 2005 (“FPO”), (ii) high net worth companies within the meaning of Article 49(2)(a) to (d) of the FPO, (iii) persons that are existing members or creditors of the issuer of the Rights Offering Securities, or of an undertaking which at the relevant time is in the same group as the issuer of the Rights Offering Securities, falling within Article 43 of the FPO or (iv) persons to whom the communication may otherwise lawfully be communicated (together, the “Permitted UK Persons”). Any person in the United Kingdom that is not a Permitted UK Person is not, for the purposes of any investment or investment decision, an intended recipient of the information contained in the Rights Offering Procedures and the Beneficial Holder Subscription Form and should not use such information as the basis for taking any investment activity or investment action. Neither the Rights Offering Procedures nor the Beneficial Holder Subscription Form should (insofar as they relate to any investment or investment activity) be distributed, communicated to, or directed at the general public in the United Kingdom otherwise than as described above.

Please consult the Plan, the Disclosure Statement and the Rights Offering Procedures

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(including the Rights Offering Instructions attached thereto) for additional information with respect to this Beneficial Holder Subscription Form. Any terms capitalized but not defined herein shall have the meaning as set forth in the Plan or the Rights Offering Procedures.

If you have any questions, please contact the Subscription Agent by emailing [email protected] or by calling one of the following phone numbers: 855-586- 3872 (Domestic) or 949-325-6215 (International).

SUBJECT TO THE TERMS AND CONDITIONS OF THE RIGHTS OFFERING PROCEDURES (AND THE BACKSTOP AGREEMENT IN THE CASE OF ANY BACKSTOP PARTY), ALL SUBSCRIPTIONS SET FORTH IN THIS BENEFICIAL HOLDER SUBSCRIPTION FORM ARE IRREVOCABLE.

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Item 1. Amount of Senior Notes

I certify that I am a beneficial owner of the aggregate principal amounts as set forth below of the Company’s 6.875% Senior Notes due 2020 (the “2020 Notes”), 7.875% Senior Notes due 2040 (the “2040 Notes” and, together with the 2020 Notes, the “Pride Notes”), 4.70% Senior Notes due 2021 (the “2021 Notes”), 8.00% Senior Notes due 2024 (the “8.00% 2024 Notes”), 4.50% Senior Notes due 2024 (the “4.50% 2024 Notes”), 5.20% Senior Notes due 2025 (the “5.20% 2025 Notes”), 7.75% Senior Notes due 2026 (the “2026 Notes”), 5.75% Senior Notes due 2044 (the “5.75% 2044 Notes” and, together with the 2021 Notes, the 8.0% 2024 Notes, the 4.50% 2024 Notes, the 5.20% 2025 Notes and the 2026 Notes, the “Valaris Notes”), 4.875% Senior Notes due 2022 (the “2022 Notes”), 4.75% Senior Notes due 2024 (the “4.75% 2024 Notes”), 7.375% Senior Notes due 2025 (the “7.375% 2025 Notes”), 5.40% Senior Notes due 2042 (the “2042 Notes”), 5.85% Senior Notes due 2044 (the “5.85% 2044 Notes” and, together with the 2022 Notes, the 4.75% 2024 Notes, the 7.375% 2025 Notes and the 2042 Notes, the “Legacy Rowan Notes”), 3.00% Exchangeable Senior Notes due 2024 (the “3.00% 2024 Notes” or the “Jersey Notes”) and/or 7.20% Debentures due 2027 (the “2027 Debentures” or the “Ensco International Debentures,” and, collectively, the Pride Notes, the Valaris Notes, the Legacy Rowan Notes and the Jersey Notes, the “Senior Notes”) in the following amounts (insert amount on the lines below) or that I am the authorized signatory of that beneficial holder. For the purposes of this Beneficial Holder Subscription Form, do not adjust the principal (face) amount for any accrued or unmatured interest. Accrued prepetition interest is accounted for in the multiplier set forth in Item 2 and Item 3a below.

Insert aggregate principal amount of Senior Notes held, as applicable.

Pride Notes

2020 Notes (CUSIP 74153QAH5/US74153QAH56):______

2040 Notes (CUSIP 74153QAJ1/US74153QAJ13):______

Valaris Notes

2021 Notes (CUSIP 91889DAA4/US91889DAA46):______

8.00% 2024 Notes (CUSIP 91889DAC0/US91889DAC02):______

4.50% 2024 Notes (CUSIP 91889DAB2/US91889DAB29):______

5.20% 2025 Notes (CUSIP 91889DAD8/US91889DAD84):______

2026 Notes (CUSIP

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91889DAE6/US91889DAE67):______

5.75% 2044 Notes (CUSIP 91889DAF3/US91889DAF33):______

Legacy Rowan Notes

2022 Notes (CUSIP G9420RAA4/USG9420RAA44):______

4.75% 2024 Notes (CUSIP G9420RAB2/USG9420RAB27):______

7.375% 2025 Notes (CUSIP G9420RAC0/USG9420RAC00):______

2042 Notes (CUSIP G9420RAD8/USG9420RAD82):______

5.85% 2044 Notes (CUSIP G9420RAE6/USG9420RAE65):______

Jersey Notes

3.00% 2024 Notes (CUSIP 29359WAB1/US29359WAB19):______

Ensco International Debentures

2027 Debentures (CUSIP 26874QAB6/US26874QAB68):______

IMPORTANT NOTE: IF YOU HOLD YOUR SENIOR NOTES THROUGH MORE THAN ONE NOMINEE, YOU MUST COMPLETE AND RETURN A SEPARATE BENEFICIAL HOLDER SUBSCRIPTION FORM TO EACH APPLICABLE NOMINEE. YOU MAY NOT AGGREGATE POSITIONS HELD BY DIFFERENT NOMINEES ON A SINGLE BENEFICIAL HOLDER SUBSCRIPTION FORM.

Item 2. Rights Calculation Worksheet

The number of Rights Offering Notes for which the undersigned may subscribe, based on the principal amount shown above, is calculated as follows:

Pride Notes

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______X 0.064862 ÷ 1000 = ______(Insert aggregate principal (Maximum number of Rights amount from Item 1 above for Offering Notes) (Round to sum of 2020 Notes) nearest whole number)

______X 0.065180 ÷ 1000 = ______(Insert aggregate principal (Maximum number of Rights amount from Item 1 above for Offering Notes) (Round to sum of 2040 Notes) nearest whole number)

Valaris Notes

______X 0.037602 ÷ 1000 = ______(Insert aggregate principal (Maximum number of Rights amount from Item 1 above for Offering Notes) (Round to sum of 2021 Notes) nearest whole number)

______X 0.038488 ÷ 1000 = ______(Insert aggregate principal (Maximum number of Rights amount from Item 1 above for Offering Notes) (Round to sum of 8.00% 2024 Notes) nearest whole number)

______X 0.037497 ÷ 1000 = ______(Insert aggregate principal (Maximum number of Rights amount from Item 1 above for Offering Notes) (Round to sum of 4.50% 2024 Notes) nearest whole number)

______X 0.037680 ÷ 1000 = ______(Insert aggregate principal (Maximum number of Rights amount from Item 1 above for Offering Notes) (Round to sum of 5.20% 2025 Notes) nearest whole number)

______X 0.038429 ÷ 1000 = ______(Insert aggregate principal (Maximum number of Rights amount from Item 1 above for Offering Notes) (Round to sum of 2026 Notes) nearest whole number)

______X 0.037672 ÷ 1000 = ______(Insert aggregate principal (Maximum number of Rights amount from Item 1 above for Offering Notes) (Round to sum of 5.75% 2044 Notes) nearest whole number)

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Legacy Rowan Notes

______X 0.048402 ÷ 1000 = ______(Insert aggregate principal (Maximum number of Rights amount from Item 1 above for Offering Notes) (Round to sum of 2022 Notes) nearest whole number)

______X 0.048089 ÷ 1000 = ______(Insert aggregate principal (Maximum number of Rights amount from Item 1 above for Offering Notes) (Round to sum of 4.75% 2024 Notes) nearest whole number)

______X 0.049103 ÷ 1000 = ______(Insert aggregate principal (Maximum number of Rights amount from Item 1 above for Offering Notes) (Round to sum of 7.375% 2025 Notes) nearest whole number)

______X 0.048578 ÷ 1000 = ______(Insert aggregate principal (Maximum number of Rights amount from Item 1 above for Offering Notes) (Round to sum of 2042 Notes) nearest whole number)

______X 0.048393 ÷ 1000 = ______(Insert aggregate principal (Maximum number of Rights amount from Item 1 above for Offering Notes) (Round to sum of 5.85% 2044 Notes) nearest whole number)

Jersey Notes

______X 0.074339 ÷ 1000 = ______(Insert aggregate principal (Maximum number of Rights amount from Item 1 above for Offering Notes) (Round to sum of 3.00% 2024 Notes) nearest whole number)

Ensco International Debentures

______X 0.043184 ÷ 1000 = ______(Insert aggregate principal (Maximum number of Rights amount from Item 1 above for Offering Notes) (Round to sum of 2027 Debentures) nearest whole number)

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Each Eligible Holder is entitled to subscribe for:

(i) 0.000064862 Rights Offering Notes per $1,000 of aggregate principal amount of the 2020 Notes;

(ii) 0.000065180 Rights Offering Notes per $1,000 of aggregate principal amount of the 2040 Notes;

(iii) 0.000037602 Rights Offering Notes per $1,000 of aggregate principal amount of the 2021 Notes;

(iv) 0.000038488 Rights Offering Notes per $1,000 of aggregate principal amount of the 8.00% 2024 Notes;

(v) 0.000037497 Rights Offering Notes per $1,000 of aggregate principal amount of the 4.50% 2024 Notes;

(vi) 0.000037680 Rights Offering Notes per $1,000 of aggregate principal amount of the 5.20% 2025 Notes;

(vii) 0.000038429 Rights Offering Notes per $1,000 of aggregate principal amount of the 2026 Notes;

(viii) 0.000037672 Rights Offering Notes per $1,000 of aggregate principal amount of the 5.75% 2044 Notes; and

(ix) 0.000048402 Rights Offering Notes per $1,000 of aggregate principal amount of the 2022 Notes;

(x) 0.000048089 Rights Offering Notes per $1,000 of aggregate principal amount of the 4.75% 2024 Notes;

(xi) 0.000049103 Rights Offering Notes per $1,000 of aggregate principal amount of the 7.375% 2025 Notes;

(xii) 0.000048578 Rights Offering Notes per $1,000 of aggregate principal amount of the 2042 Notes;

(xiii) 0.000048393 Rights Offering Notes per $1,000 of aggregate principal amount of the 5.85% 2044 Notes,

(xiv) 0.000074339 Rights Offering Notes per $1,000 of aggregate principal amount of the 3.00% 2024 Notes; and/or

(xv) 0.000043184 Rights Offering Notes per $1,000 of aggregate principal amount of the 2027 Debentures; subject to the individual limits included in the calculations in the table above, as applicable.

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IMPORTANT NOTE: You may exercise any portion of principal amount of Senior Notes that you wish, up to the total amount shown for this account, subject to the terms and conditions of the Rights Offering Procedures. You must hold at least $1,000 principal amount of Senior Notes of any particular Senior Notes issuance in order to exercise at least one Subscription Right with respect to such issuance. The exercise of rights will be effected through the submission of the relevant amount of underlying Senior Notes through The Depository Trust Company (“DTC”) Automated Tender Offer Program (“ATOP”), which will also block your underlying Senior Notes from trading. If you do not wish to exercise 100% of your available rights based on the principal amount in Item 1, you should instruct your Nominee to only submit the amount of Senior Notes associated with the number of rights you wish to exercise. For example, if you only wish to exercise 50% of your rights, you should instruct your Nominee to only submit 50% of your Senior Notes via ATOP.

Item 3. Rights Exercise

To subscribe, fill out all Items in this Beneficial Holder Subscription Form completely and legibly – and follow the instructions of your Nominee with respect to the submission of your instructions to the Nominee.

3a. Exercise Instruction. Principal Amount that you wish your Nominee to SUBMIT VIA ATOP for the purpose of exercising rights. The principal amount of Senior Notes you instruct your Nominee to submit via ATOP and (if calculated correctly) the corresponding number of Rights Offering Notes for which you wish to subscribe are shown below:

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Rights Offering Notes:

BOX A BOX B

______X 0.064862 ÷ 1000 = ______(Number of associated Rights (Insert principal amount of Offering Notes) (Round to 2020 Notes you request your nearest whole number) Nominee to SUBMIT VIA ATOP in order to exercise the associated Rights) (May not be more than the Principal Amount shown in Item 2)

______X 0.065180 ÷ 1000 = ______(Number of associated Rights (Insert principal amount of Offering Notes) (Round to 2040 Notes you request your nearest whole number) Nominee to SUBMIT VIA ATOP in order to exercise the associated Rights) (May not be more than the Principal Amount shown in Item 2)

______X 0.037602 ÷ 1000 = ______(Number of associated Rights (Insert principal amount of Offering Notes) (Round to 2021 Notes you request your nearest whole number) Nominee to SUBMIT VIA ATOP in order to exercise the associated Rights) (May not be more than the Principal Amount shown in Item 2)

______X 0.038488 ÷ 1000 = ______(Number of associated Rights (Insert principal amount of Offering Notes) (Round to 8.00% 2024 Notes you request nearest whole number) your Nominee to SUBMIT VIA ATOP in order to exercise the associated Rights) (May not be more than the Principal Amount shown in Item 2)

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______X 0.037497 ÷ 1000 = ______(Number of associated Rights (Insert principal amount of Offering Notes) (Round to 4.50% 2024 Notes you request nearest whole number) your Nominee to SUBMIT VIA ATOP in order to exercise the associated Rights) (May not be more than the Principal Amount shown in Item 2)

______X 0.037680 ÷ 1000 = ______(Number of associated Rights (Insert principal amount of Offering Notes) (Round to 5.20% 2025 Notes you request nearest whole number) your Nominee to SUBMIT VIA ATOP in order to exercise the associated Rights) (May not be more than the Principal Amount shown in Item 2)

______X 0.038429 ÷ 1000 = ______(Number of associated Rights (Insert principal amount of Offering Notes) (Round to 2026 Notes you request your nearest whole number) Nominee to SUBMIT VIA ATOP in order to exercise the associated Rights) (May not be more than the Principal Amount shown in Item 2)

0.037672 ______X ÷ 1000 = ______(Number of associated Rights (Insert principal amount of Offering Notes) (Round to 5.75% 2044 Notes you request nearest whole number) your Nominee to SUBMIT VIA ATOP in order to exercise the associated Rights) (May not be more than the Principal Amount shown in Item 2)

______X 0.048402 ÷ 1000 = ______(Number of associated Rights (Insert principal amount of Offering Notes) (Round to 2022 Notes you request your nearest whole number) Nominee to SUBMIT VIA ATOP in order to exercise the associated Rights) (May not be more than the Principal Amount shown in Item 2)

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______X 0.048089 ÷ 1000 = ______(Number of associated Rights (Insert principal amount of Offering Notes) (Round to 4.75% 2024 Notes you request nearest whole number) your Nominee to SUBMIT VIA ATOP in order to exercise the associated Rights) (May not be more than the Principal Amount shown in Item 2)

______X 0.049103 ÷ 1000 = ______(Number of associated Rights (Insert principal amount of Offering Notes) (Round to 7.375% 2025 Debentures you nearest whole number) request your Nominee to SUBMIT VIA ATOP in order to exercise the associated Rights) (May not be more than the Principal Amount shown in Item 2)

______X 0.048578 ÷ 1000 = ______(Number of associated Rights (Insert principal amount of Offering Notes) (Round to 2042 Notes you request your nearest whole number) Nominee to SUBMIT VIA ATOP in order to exercise the associated Rights) (May not be more than the Principal Amount shown in Item 2)

______X 0.048393 ÷ 1000 = ______(Number of associated Rights (Insert principal amount of Offering Notes) (Round to 5.85% 2044 Notes you request nearest whole number) your Nominee to SUBMIT VIA ATOP in order to exercise the associated Rights) (May not be more than the Principal Amount shown in Item 2)

______X 0.074339 ÷ 1000 = ______(Number of associated Rights (Insert principal amount of Offering Notes) (Round to 3.00% 2024 Notes you request nearest whole number) your Nominee to SUBMIT VIA ATOP in order to exercise the associated Rights) (May not be more than the Principal Amount shown in Item 2)

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______X 0.043184 ÷ 1000 = ______(Number of associated Rights (Insert principal amount of Offering Notes) (Round to 2027 Debentures you request nearest whole number) your Nominee to SUBMIT VIA ATOP in order to exercise the associated Rights) (May not be more than the Principal Amount shown in Item 2)

BOX C Total Number of Rights Offering Notes: ______

Rights Offering Shares

The number of associated Rights Offering Shares to which the undersigned is entitled, based on the exercised Subscription Rights shown above, is calculated as follows1:

______X 45 = ______(Insert Total Number of Rights (Number of associated Rights Offering Offering Notes shown in Box C of Shares) Item 3a)

Total Number of Rights Offering Shares: ______

3b. Calculation of Purchase Price. By filling in the following blanks, you are indicating that the undersigned Eligible Holder is subscribing to purchase the number of Rights Offering Notes associated with the Principal Amount specified in Box A (which, if calculated correctly, will yield the Total Number of Rights Offering Notes shown in Box C and the associated Rights Offering Shares at the aggregate Purchase Price shown in Box D (the “Aggregate Purchase Price”)), on the terms and subject to the conditions set forth in the Rights Offering Procedures.

BOX D

______X $1000 = $______(Insert Total Number of Rights Aggregate Purchase Price (include Offering Notes from Box C dollars and cents) above)

For the avoidance of doubt, the exercise of Rights Offering Notes will be based solely upon the PRINCIPAL AMOUNT tendered, and not on the amounts shown in Box C or Box D, which are included for your convenience.

1 Based on an estimated 75 million shares of New Valaris Equity issued and outstanding immediately after the Effective Date, which amount may be subject to change.

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Item 4. Payment and Delivery Instructions

Insert Aggregate Purchase Price as set forth in BOX D: $______

For Eligible Holders that did not check the box in Item 6 below, payment of the Aggregate Purchase Price calculated pursuant to Item 3b above shall be made by wire transfer ONLY of immediately available funds in accordance with the following wire instructions:

Domestic/International wire:

Account Name: Bankruptcy Management Solutions, Inc. DBA Stretto F/B/O Valaris Subscription Bank Account No.: 1504288966 ABA/Routing No.: 026013576 SWIFT: SIGNUS33 Bank Name: SIGNATURE BANK Bank Address: 565 5th Ave, 12th Fl New York, NY 10017 Bank Phone Number: 866-744-5463 Reference: DTC Participant Number and VOI Number

For all Eligible Holders who are not Backstop Parties, payment of the Aggregate Purchase Price shown in Box D above must be made by the Subscription Payment Deadline.

Eligible Holders who are Backstop Parties shall not be required to pay their respective Aggregate Purchase Price until required in accordance with the terms of the Backstop Agreement, as amended.

THE PAYMENT MUST BE MADE BY ELIGIBLE HOLDERS THAT ARE NOT BACKSTOP PARTIES BY THE SUBSCRIPTION PAYMENT DEADLINE.

Please provide your completed Beneficial Holder Subscription Form (or other required instruction, as applicable) to your Nominee in sufficient time to allow such Nominee to deliver the aggregate principal amount of Senior Notes shown in Box A via ATOP by the Subscription Instruction Deadline. The Aggregate Purchase Price associated with the number of Senior Notes tendered via ATOP must be made by the Subscription Payment Deadline, unless you are a Backstop Party.

PLEASE NOTE: NO SUBSCRIPTION WILL BE VALID UNLESS THE RELEVANT SENIOR NOTES HAVE BEEN TENDERED THROUGH ATOP BY THE SUBSCRIPTION INSTRUCTION DEADLINE.

PAYMENT MUST BE MADE BY ELIGIBLE HOLDERS THAT ARE NOT BACKSTOP PARTIES BY THE SUBSCRIPTION PAYMENT DEADLINE.

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Item 5. Certification.

The undersigned hereby certifies that it (i) is the beneficial owner of the Senior Notes set forth in Item 1 above (the “Holder”), or the authorized signatory (the “Authorized Signatory”) of such Holder acting on behalf of the Holder, (ii) is entitled to participate in the Rights Offering, (iii) has reviewed a copy of the Plan, the Disclosure Statement and the Rights Offering Procedures (including the Rights Offering Instructions attached thereto) and other applicable materials and (iv) understands that the exercise of the rights under the Rights Offering is subject to all the terms and conditions set forth in the Plan and the Rights Offering Procedures.

Please provide your completed Beneficial Holder Subscription Form (or other required instruction, as applicable) to your Nominee in sufficient time to allow such Nominee to deliver the principal amount shown in Box A via ATOP by the Subscription Instruction Deadline. By electing to subscribe for the Total Number of Rights Offering Notes shown in Box B above, the Holder (or the Authorized Signatory on behalf of the Holder) is hereby instructing its Nominee to arrange for the delivery of the Senior Notes shown in Box A via ATOP by the Subscription Instruction Deadline, and acknowledges that payment of the Aggregate Purchase Price shown in Box D associated with that the delivery of such Senior Notes must be made by Eligible Holders that are not Backstop Parties by the Subscription Payment Deadline.

The Holder (or the Authorized Signatory on behalf of such Holder) acknowledges that, by executing this Beneficial Holder Subscription Form or otherwise providing its subscription instructions to its Nominee, the Eligible Holder has elected to subscribe for the number of Rights Offering Notes associated with the principal amount tendered through ATOP, and will be bound to pay the Aggregate Purchase Price for the Rights Offering Notes it has subscribed for and that it may be liable to the Debtors to the extent of any nonpayment.

Date: ______

Name of Eligible Holder: ______

Signature: ______

Name of Signatory: ______

Title: ______

Telephone Number: ______

Email: ______

Item 6. Backstop Party Representation.

(This section is only for Backstop Parties, each of whom is aware of its status as a Backstop Party. If you are a Backstop Party, a fully completed Backstop Party Addendum MUST be

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provided to your Nominee. A Backstop Party Addendum will be forwarded to each Backstop Party, and the Backstop Party is responsible for forwarding it to their Nominee who will confirm that payment does not have to be made prior to the Subscription Payment Deadline. Please note that checking the box below if you are not a Backstop Party may result in forfeiture of your rights to participate in the Rights Offering.)

□ I am a Backstop Party identified in the Backstop Agreement and, if applicable, the Backstop Party Addendum has been provided to my Nominee.

Item 7. Representations, Warranties and Agreements.

In order to participate in the Rights Offering, you must complete this question. Any person that is not an Eligible Holder is not eligible to participate in the Rights Offering.

The undersigned certifies that:

(1) It and, where relevant, the Holder, is not resident of, or located in, a member state of the EEA or the United Kingdom (each a “Relevant State”).

YES NO

(2) It and, where relevant, the Holder, is resident of, or located in, a Relevant State and is a Qualified Investor (as defined in the Prospectus Regulation).

YES NO

(3) It and, where relevant, the Holder, is resident of, or located in, a Relevant State and is not a Qualified Investor (as defined in the Prospectus Regulation). If “Yes”, please specify the Relevant State clearly.

YES NO

RELEVANT STATE

For the purposes of this Item 7:

“Eligible Holder” means, with respect to any person or entity that is a resident of, or located in, a Relevant State, Qualified Investors or natural or legal persons (other than Qualified Investors) if the Company determines, in its discretion, that such persons constitute Eligible Holders, subject to no more than 149 natural or legal persons (other than Qualified Investors) in any Relevant State being offered or permitted to acquire Rights Offering Notes.

The Rights Offering Notes are only offered and available to 149 natural or legal persons or entities (other than Qualified Investors) in any Relevant State and the right to subscribe to the Rights Offering Notes is accordingly limited.

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“Holder” means the beneficial owner of the Senior Notes set forth in Item 1 above.

“Prospectus Regulation” means Regulation (EU) 2017/1129.

Item 8. Tender of Senior Notes; Exercise Instruction.

All Eligible Holders of Senior Notes that exercise Subscription Rights in respect of Senior Notes Claims must direct their Nominee to electronically tender their applicable underlying Senior Notes in the following principal amount(s) to an account of the Subscription Agent via ATOP in order to participate in the Rights Offering (to the extent of such participation). Nominees must tender Eligible Holders’ Senior Notes on a per holder basis. Nominees may not submit bulk tender instructions.

To Be Completed by Nominee Only

(Evidence of electronic delivery of Senior Notes via ATOP held through DTC)

CUSIP / ISIN Security Principal Name & DTC ATOP Euroclear or Description Amount of DTC # of Confirmation Clearstream Senior Nominee Number Reference Notes Holding (VOI) Number (If Tendered Position at Applicable) into ATOP DTC

74153QAH5/US74153QAH56 2020 Notes $

74153QAJ1/US74153QAJ13 2040 Notes $

91889DAA4/US91889DAA46 2021 Notes $

91889DAC0/US91889DAC02 8.00% 2024 $ Notes

91889DAB2/US91889DAB2 4.50% 2024 $ Notes

91889DAD8/US91889DAD84 5.20% 2025 $ Notes

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91889DAE6/US91889DAE67 2026 Notes $

91889DAF3/US91889DAF33 5.75% 2044 $ Notes

G9420RAA4/USG9420RAA44 2022 Notes $

G9420RAB2/USG9420RAB27 4.75% 2024 $ Notes

G9420RAC0/USG9420RAC00 7.375% 2025 $ Notes

G9420RAD8/USG9420RAD82 2042 Notes $

G9420RAE6/USG9420RAE65 5.85% 2044 $ Notes

29359WAB1/US29359WAB19 3.00% 2024 $ Notes

26874QAB6/US26874QAB68 2027 Debentures

Item 9. Registration Information

Please indicate on the lines provided below the registration name of the Eligible Holder in whose name the Rights Offering Securities should be issued, in the event the Rights Offering Securities are not DTC eligible (it is strongly recommended that the below information be typed to ensure that it is legible). Please also select the “account type” into which the Rights Offering Securities will be issued:

Registration Name Line 1 (Maximum 35 Characters):______Registration Name Line 2 (Maximum 35 Characters):______(if needed) Address 1:______Address 2:______Address 3:______City, State, Postal Code:______Telephone:______Email: ______U.S. Tax Identification Number: ______Check here if non-US (no TIN)

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INDIVIDUAL ACCOUNT; IRA ACCOUNT;

CORPORATIONS (S-CORP): (ASSOCIATED, ASSOCIATES, ASSOCIATION, CO, CO. COMPANY, CORP, CORPORATE/PARTNER, ENTERPRISE(S), FUND, GROUP, INCORPORATED, INC, INTERNATIONAL, INTL, LIMITED, LTD, LIFETIME LIMITED COMPANY, LLC, L.L.C., PARTNER, PARTNERS, PLC, PUBLIC LIMITED COMPANY);

PARTNERSHIP: (LP, L P, L.P., LLP, LIMITED PARTNERSHIP, LIFETIME LIMITED PARTNERSHIP);

BANK;

NOMINEE ACCOUNTS;

THE NEW C-CORP;

NON-PROFIT: (CEMETERY, CHURCH, COLLEGE, COMMISSION FOR CHILDREN WITH, COMMISSION FOR HANDICAPPED, COMMISSION MINISTRIES INC, COMMISSION OF PUBLIC WORKS, COMMISSION OF BANKING & FOUNDATIONS, HOSPITAL, SCHOOL, SYNAGOGUE, UNIVERSITY);

FIDUCIARY ACCOUNT: (CUSTODIAN, CO-TRUSTEE, ESTATE, EXECUTOR, EXECUTRIX FBO, F/B/O, FAO, FIDUCIARY TRUST, ITF, LIFE TEN, PENSION PLAN, INDIVIDUAL NAME PROFIT SHARING PLAN, RETIREMENT PLAN, 401K PLAN, SELL TRANSFER PLEDGE, STATE UNIFORM TRANSFER RO MINOR’S ACT, TTEE, TTEES, UW, UTMA, UGMA, USUFRUCT, UNIFIED, UNIF GIFT MIN ACT, UNIF TRUST MIN ACT, UNIFIED GIFT TO MINORS ACT, UNIFORM GIFT TO MINORS, UNIFORM TRANSFER TO MINORS, GRAT (GRANTOR ANNUITY TRUST);

TENANTS IN COMMON;

TENANTS BY ENTIRETY: (TEN ENT, TENANTS ENT, TENANTS ENTIRETY, TENANTS BY ENTIRETY, TENANTS BY ENTIRETIES);

JOINT TENANTS: (JT TEN, JT TEN WROS, JT WROS, J/T/W/R/S, JOINT TENANCY, JOINT TENANTS WITH RIGHT OF SURVIVORSHIP, JT OWNERSHIP, IF JT ACCOUNT WITH TOD); or

COMMUNITY PROPERTY: (COM PROP, COMM PROP, COM PROPERTY, COMM PROPERTY, MARITAL PROPERTY, HWACP, HUSBAND & WIFE AS COMMUNITY PROPERTY).

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Item 10. Wire information in the event a refund is needed:

Account Name: Bank Account No.: ABA/Routing No.: Bank Name: Bank Address: Reference:

Once completed, you must return this Beneficial Holder Subscription Form (or other form of instruction required by your Nominee) to your Nominee in accordance with your Nominee’s instructions in sufficient time for your Nominee to tender your Senior Notes to the account of the Subscription Agent through DTC’s ATOP system at or before the Subscription Instruction Deadline.

PLEASE RETURN THIS BENEFICIAL HOLDER SUBSCRIPTION FORM OR OTHER INSTRUCTION (AS REQUIRED BY THE NOMINEE) ONLY TO YOUR NOMINEE. DO NOT RETURN THIS FORM DIRECTLY TO THE SUBSCRIPTION AGENT, UNLESS YOUR NOMINEE HAS ALREADY TENDERED YOUR SENIOR NOTES THROUGH ATOP AND THE RELATED VOI NUMBER(S) ARE PROVIDED ON THIS BENEFICIAL HOLDER SUBSCRIPTION FORM.

THE SUBSCRIPTION AGENT MUST BE IN RECEIPT OF THIS BENEFICIAL HOLDER SUBSCRIPTION FORM BY THE SUBSCRIPTION INSTRUCTION DEADLINE.

Return completed documents to: Preferred Method If submitting via email: [email protected] Valaris plc, et at., Rights Offering. c/o Stretto 410 Exchange, Suite 100 Irvine, California 92602

The method of delivery of the applicable Beneficial Holder Subscription Form (or other form of instruction required by your Nominee) and any other required documents is at each Eligible Holder’s option and sole risk. Eligible Holders of Senior Notes Claims must ensure that their Nominee tenders their Senior Notes at or prior to the Subscription Instruction Deadline and, except for Eligible Holders who are Backstop Parties, coordinate payment of the Purchase Price.

PLEASE NOTE: THE SUBSCRIPTION WILL NOT BE VALID UNLESS THE

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RELEVANT SENIOR NOTES HAVE BEEN TENDERED THROUGH ATOP BY THE SUBSCRIPTION INSTRUCTION DEADLINE.

PAYMENT MUST MADE BY ELIGIBLE HOLDERS THAT ARE NOT BACKSTOP PARTIES BY THE SUBSCRIPTION PAYMENT DEADLINE.

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BACKSTOP PARTY ADDENDUM

The undersigned certifies that the undersigned is a party to that certain Backstop Commitment Agreement, dated August 18, 2020, by and among Valaris plc, the other Debtors party thereto and the Backstop Parties party thereto, and therefore is not required to submit payment in connection with the Rights Offering prior to the Subscription Payment Deadline. An Eligible Holder that is a Backstop Party must provide its payment in accordance with Section 2.4 of the Backstop Agreement. If you are a Backstop Party, please instruct your Nominee to submit a properly executed Backstop Party Addendum along with the Subscription Form. The information in the table below should be identical to the information provided in Item 8 of the Subscription Form.

IN WITNESS WHEREOF, the undersigned has executed this addendum on and as of the ___ day of ______, 2021.

If an Entity:

Name of Entity: ______

Signature: ______By: ______Its: ______State or Country of Principal Place of Business: ______Address: ______Fax: ______E-mail ______US Tax ID/EIN: ______OR Check here if non-US (no TIN) ☐

If an Individual Investor:

Name of Individual: ______

Signature: ______State or Country of Primary Residence: ______Address: ______Fax: ______E-mail ______US Tax ID/EIN: ______OR Check here if non-US (no TIN) ☐

To Be Completed by Nominee Only (Evidence of electronic delivery of Senior Notes via ATOP held through DTC) CUSIP / ISIN Security Description Principal Amount of Name & DTC # of DTC ATOP Euroclear or Senior Notes Tendered Nominee Holding Confirmation Number Clearstream Reference into ATOP Position at DTC (VOI) Number (If Applicable)

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Exhibit C

Case 20-34114 Document 947 Filed in TXSB on 01/12/21 Page 47 of 58 Exhibit C Served Via Overnight Mail

Name Attention Address 1 Address 2 Address 3 City State Zip ProxyTrust Attn Receiving Department 100 Patco Court Suite 9 Islandia NY 11749 FOLIOfn, Inc. 8180 Greensboro Drive 8th Floor McLean VA 22102 Depository Trust Company 570 Washington Blvd. Attn Reorg Dept 4th Floor Jersey City NJ 07310

In re: Valaris plc, et al. Case No. 20-34114 (MI) Page 1 of 1 Case 20-34114 Document 947 Filed in TXSB on 01/12/21 Page 48 of 58

Exhibit D

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Exhibit D Served Via First-Class Mail

Name Attention Address 1 Address 2 Address 3 City State Zip Country ABN AMRO CLEARING CHICAGO LLC KIM VILARA 175 W. JACKSON BLVD SUITE 400 CHICAGO IL 60605 ALBERT FRIED & COMPANY, LLC ATTN: ANTHONY KATSINGRIS 45 BROADWAY 24TH FLOOR NEW YORK NY 10006 AMALGAMATED BANK CORPORATE ACTIONS 275 Seventh Avenue NEW YORK NY 10011 AMALGAMATED BANK STEPHEN ERB 275 SEVENTH AVENUE 9TH FLOOR NEW YORK NY 10001 AMERICAN ENTERPRISE INVESTMENT SERVI GREG WRAALSTAD 901 3RD AVE SOUTH MINNEAPOLIS MN 55474

AMERICAN ENTERPRISE INVESTMENT SERVICES INC. ATTN: CORPORATE ACTIONS 2178 AMERIPRISE FINANCIAL ROUTING S6/2178 MINNEAPOLIS MN 55474

AMERICAN ENTERPRISE INVESTMENT SERVICES INC. ATTN: PENNY ZALESKY 2178 AMERIPRISE FINANCIAL CENTER ROUTING: S6/2178 MINNEAPOLIS MN 55474

AMERICAN ENTERPRISE INVESTMENT SERVICES INC. ATTN: REORG DEPARTMENT 2178 AMERIPRISE FINANCIAL CENTER ROUTING: S6/2178 MINNEAPOLIS MN 55474

AMERICAN ENTERPRISE INVESTMENT SERVICES INC. ERIN M STIELER 682 AMP FINANCIAL CENTER MINNEAPOLIS MN 55474

AMERICAN ENTERPRISE INVESTMENT SERVICES INC. GREG WRAALSTAD CORPORATE ACTIONS 901 3RD AVE SOUTH MINNEAPOLIS MN 55474 APEX CLEARING CORPORATION 1700 PACIFIC AVENUE STE 1400 DALLAS TX 75201 APEX CLEARING CORPORATION ATTN: BILIANA STOIMENOVA 1700 PACIFIC AVENUE SUITE 1400 DALLAS TX 75201 APEX CLEARING CORPORATION ATTN: BRIAN DARBY ONE DALLAS CENTER 350 M. ST. PAUL, SUITE 1300 DALLAS TX 75201 BANK OF AMERICA NA/CLIENT ASSETS PHILLIP DUQUIN 135 SOUTH LASALLE STREET SUITE 1860 CHICAGO IL 60603 BANK OF AMERICA, NA/GWIM TRUST OPERA SHARON BROWN 1201 MAIN STREET 9TH FLOOR DALLAS TX 75202 BANK OF AMERICA, NA/GWIM TRUST OPERATIONS SHARON BROWN 1201 MAIN STREET 9TH FLOOR DALLAS TX 75202 BARCLAYS BANK PLC NEW YORK BRANCH BARCLAYSBANK PLC-LNBR ANTHONY SCIARAFFO 1301 SIXTH AVE NEW YORK NY 10019 BARCLAYS BANK PLC NEW YORK BRANCH BARCLAYSBANK PLC-LNBR CORPORATE ACTIONS 200 CEDAR KNOLLS ROAD WHIPPANY NJ 07981 BARCLAYS CAPITAL INC./LE ANTHONY SCIARAFFO CORPORATE ACTIONS 400 JEFFERSON PARK WHIPPANY NJ 07981 BARCLAYS CAPITAL INC./LE ANTHONY SCIARAFFO 1301 SIXTH AVE NEW YORK NY 10019 BARCLAYS CAPITAL INC./LE GIOVANNA LAURELLA VICE PRESIDENT 70 HUDSON STREET 7TH FLOOR JERSEY CITY NJ 07302 BB&T SECURITIES, LLC ATTN: CORPORATE ACTIONS 200 S. COLLEGE ST, 8TH FLOOR CHARLOTTE NC 28202 BB&T SECURITIES, LLC ATTN: MARY GLASSCOCK 8006 DISCOVERY DRIVE RICHMOND VA 23229-8600 BB&T SECURITIES, LLC JESSE W. SPROUSE 8006 DISCOVERY DRIVE SUITE 200 RICHMOND VA 23229 BBS SECURITIES INC./CDS** CORPORATE ACTIONS 4100 YONGE STREET SUITE 415 TORONTO ON M2P 2B5 CANADA BBS SECURITIES INC./CDS** CORPORATE ACTIONS DEBORAH CARLYLE 4100 YONGE STREET SUITE 504A TORONTO ON M2P 2G2 CANADA BETA CAPITAL SECURITIES LLC 777 BRICKELL AVENUE SUITE 1201 MIAMI FL 33131 BMO CAPITAL MARKETS CORP. CORPORATE ACTIONS 250 YONGE ST. 8TH FLOOR TORONTO ON M5B 2M8 CANADA BMO CAPITAL MARKETS CORP. RONALD FIGUERAS 3 SECOND ST. 12TH FLOOR HARBORSIDE PLAZA 10 JERSEY cITY NJ 07302 BMO HARRIS BANK NA/TRUST ISSUER SERVICES 51 MERCEDES WAY EDGEWOOD NY 11717 BMO NESBITT BURNS INC./CDS** CORPORATE ACTIONS PHUTHORN PENIKETT 250 YONGE STREET 14TH FLOOR TORONTO ON M5B 2M8 CANADA 1 FIRST CANADIAN PLACE, BMO NESBITT BURNS INC./CDS** CORPORATE ACTIONS LOUISE TORANGEAU; PHUTHORN PENIKETT 13TH FL PO BOX 150 TORONTO ON M5X 1H3 CANADA BMO NESBITT BURNS INC./CDS** LOUISE TORANGEAU 1 FIRST CANADIAN PLACE 13TH FL P. O. BOX 150 TORONTO ON M5X 1H3 CANADA BNP PARIBAS, NEW YORK BRANCH/BNP PAR RONALD PERSAUD 525 WASHINGTON BLVD 9TH FLOOR JERSEY CITY NJ 07310 BNP PARIBAS, NEW YORK BRANCH/BNP PARIBAS PRIME BROKERAGE CUSTODIAN RONALD PERSAUD 525 WASHINGTON BLVD 9TH FLOOR JERSEY CITY NJ 07310 BNP PARIBAS, NEW YORK BRANCH/BNPP SA RUPERT KENNEDY ANALYST 787 7TH AVENUE 8TH FLOOR NEW YORK NY 10019 BNP PARIBAS, NEW YORK BRANCH/CUSTODY/CLIENTASSETS DEAN GALLI CORPORATE ACTIONS AD. D. JOAO II N. 49 LISBON 1988-028 PORTUGAL BNP PARIBAS, NEW YORK BRANCH/CUSTODY/CLIENTASSETS RUSSELL YAP CORPORATE ACTIONS 525 WASHINGTON BLVD 9TH FLOOR JERSEY CITY NJ 07310 BNP PARIBAS, NY BRANCH/ BNPP SA RUPERT KENNEDY ANALYST 787 7TH AVENUE 8TH FLOOR NEW YORK NY 10019 BNY MELLON WEALTH MANAGEMENT CORPORATE ACTIONS KEVIN KELLY ONE WALL STREET NEW YORK NY 10005 BNY MELLON WEALTH MANAGEMENT OPERATIONS DEPT BETH COYLE TWO BNY MELLON CENTER SUITE 1215 PITTSBURGH PA 15222 BNYMELLON/CACEIS BANK LUXEMBOURG CORP ACTIONS 525 WILLIAM PENN PLACE PITTSBURGH PA 15259 BNYMELLON/CACEIS BANK LUXEMBOURG MITCHEL SOBEL CORPORATE ACTIONS 401 SOUTH SALINA STREET 2ND FLOOR SYRACUSE NY 13202 BNYMELLON/RE CHARLES STANLEY AND COM MICHAEL KANIA VICE PRESIDENT 525 WILLIAM PENN PLACE PITTSBURGH PA 15259 BNYMELLON/RE MIDCAP SPDRS JENNIFER MAY ASSISTANT VICE PRESIDENT 525 WILLIAM PENN PLACE PITTSBURGH PA 15259 BNYMELLON/WEALTH MANAGEMENT KEVIN KELLY CORPORATE ACTIONS ONE MELLON BANK CENTER 4TH FLOOR- 151-0440 PITTSBURGH PA 15258 BNYMELLON/WEALTH MANAGEMENT MICHAEL KANIA CORP ACTIONS 525 WILLIAM PENN PLACE SUITE 1215 PITTSBURGH PA 15259 BRANCH BANKING AND TRUST COMPANY CORP ACTIONS 200 S. COLLEGE ST, 8TH FLOOR CHARLOTTE NC 28202 BRANCH BANKING AND TRUST COMPANY TANJI BASS TEAM LEADER 223 W. NASH STREET 3RD FLOOR WILSON NC 27893 BROWN BROTHERS HARRIMAN & CO. JERRY TRAVERS 525 WASHINGTON BLVD. JERSEY CITY NJ 07310 CALDWELL SECURITIES LTD./CDS** BRENDA HORSFORD 150 KING STREET WEST SUITE 1710 TORONTO ON M5H 1J9 CANADA CALDWELL TRUST COMPANY 201 CENTER ROAD SUITE 2 VENICE FL 34285 CALDWELL TRUST COMPANY ASHLEY R HARRISON 201 CENTER ROAD SUITE 2 VENICE FL 34285 CANACCORD GENUITY CORP./CDS** BEN THIESSEN 2200-609 GRANVILLE STREET VANCOUVER BC V7Y 1H2 CANADA CDS CLEARING AND DEPOSITORY SERVICES LORETTA VERELLI 600 BOUL.DE MAISONNEUVE OUEST BUREAU 210 MONTREAL QC H3A 3J2 CANADA CDS CLEARING AND DEPOSITORY SERVICES INC.** LORETTA VERELLI 600 BOUL.DE MAISONNEUVE OUEST BUREAU 210 MONTREAL QC H3A 3J2 CANADA CETERA INVESTMENT SERVICES LLC ANGELA HANDELAND SUPERVISOR 400 1ST STREET SOUTH SUITE 300 ST. CLOUD MN 56301 CETERA INVESTMENT SERVICES LLC ATTN: ASHLEY ROELIKE CORPORATE ACTIONS 400 1ST STREET SOUTH SUITE 300 ST. CLOUD MN 56301 CHARLES SCHWAB & CO., INC. CHRISTINA YOUNG 2423 E LINCOLN DRIVE PHOENIX AZ 85016-1215 CHARLES SCHWAB & CO., INC. Corporate Actions Dept.: 01-1B572 Christina Young 2423 E LINCOLN DRIVE PHOENIX AZ 85016-1215 CANADIAN IMPERIAL BANK OF 22 FRONT ST. W. 7TH CIBC WORLD MARKETS INC./CDS** CORPORATE ACTIONS RODERICK ROOPSINGH COMMERCE FL (ATTN. CORP. ACT) TORONTO ON M5J 2W5 CANADA CITIBANK, N.A. PAUL WATTERS 3801 CITIBANK CENTER B/3RD FLOOR/ZONE 12 TAMPA FL 33610 CITIBANK, N.A. SHERIDA SINANAN 3801 CITIBANK CENTER B/3RD FLOOR/ZONE 12 TAMPA FL 33610 CITIGROUP GLOBAL MARKETS INC./SALOMO SHERRYL NASH-COOK 388 GREENWICH STREET 11TH FLOOR NEW YORK NY 10013

In re: Valaris plc, et al. Case No. 20-34114 (MI) Page 1 of 6 Case 20-34114 Document 947 Filed in TXSB on 01/12/21 Page 50 of 58

Exhibit D Served Via First-Class Mail

Name Attention Address 1 Address 2 Address 3 City State Zip Country CITIGROUP GLOBAL MARKETS INC./SALOMON BROTHERS ATTN: CORPORATE ACTIONS 111 WALL STREET 6TH FLOOR NEW YORK NY 10005 CITIGROUP GLOBAL MARKETS INC./SALOMON BROTHERS CORPORATE ACTIONS DEPARTMENT 388 GREENWICH STREET 11TH FLOOR NEW YORK NY 10013 CITIGROUP GLOBAL MARKETS, INC./CORRESPONDENT CLEARING CORRESPONDENT CLEARING ABIGAIL DAVIES 388 GREENWICH STREET 11TH FLOOR NEW YORK NY 10013 CLEARSTREAM BANKING AG NICO STAES MERGENTHALLERALLEE 61 ESCBORN D-65760 GERMANY, FEDER A CLEARSTREAM BANKING AG NICO STAES MERGENTHALLERALLEE 61 GERMANY, FEDER A COMERICA BANK GLORIA IMHOFF 411 WEST LAFAYETTE DETROIT MI 48226 COMPUTERSHARE TRUST COMPANY, N.A./DR KEVIN FLEMING MANAGER 250 ROYALL STREET CANTON MA 02021 COMPUTERSHARE TRUST COMPANY, N.A./DRP KEVIN FLEMING MANAGER 250 ROYALL STREET CANTON MA 02021 COR CLEARING LLC ANH MECHALS 9300 UNDERWOOD AVENUE SUITE 400 OMAHA NE 68114 COR CLEARING LLC ISSUER SERVICES 8000 REGENCY PARKWAY CARY NC 27518 COR CLEARING LLC ISSUER SERVICES C/O MEDIANT COMMUNICATION 8000 REGENCY PARKWAY CARY NC 27518 COR CLEARING LLC LUKE HOLLAND 1200 LANDMARK CENTER SUITE 800 OMAHA NE 68102 COR CLEARING LLC/STOCK LOAN SHAWN BROWN MANAGER 9300 UNDERWOOD AVE OMAHA NE 68114 CREDENTIAL SECURITIES INC./CDS** CORPORATE ACTIONS 700 – 1111 WEST GEORGIA ST VANCOUVER BC V6E 4T6 CANADA GLOBAL PROXY RESEARCH CREDIT SUISSE SECURITIES (USA) LLC ANTHONY MILO VICE PRESIDENT 7033 LOUIS STEVENS DRIVE SERVICES TRIANGL NC 27560 GLOBAL PROXY RESEARCH CREDIT SUISSE SECURITIES (USA) LLC ANTHONY MILO VICE PRESIDENT 7033 LOUIS STEVENS DRIVE SERVICES TRIANGLE PARK NC 27709 CREDIT SUISSE SECURITIES (USA) LLC C/O BROADRIDGE 51 MERCEDES WAY EDGEWOOD NY 11717 CREST INTERNATIONAL NOMINEES LIMITED NATHAN ASHWORTH 33 CANNON STREET LONDON UK EC4M 5SB UNITED KINGDOM CREWS & ASSOCIATES, INC. CORPORATE ACTIONS 521 PRESIDENT CLINTON AVE., SUITE 800 LITTLE ROCK AR 72201-1747 D. A. DAVIDSON & CO. ATTN: CORPORATE ACTIONS 8 THIRD STREET NORTH GREAT FALLS MT 59401 D. A. DAVIDSON & CO. ATTN: DEBBIE GYGER 8 THIRD STREET NORTH GREAT FALLS MT 59401 D. A. DAVIDSON & CO. RITA LINSKEY 8 THIRD STREET NORTH GREAT FALLS MT 59401 DAVENPORT & COMPANY LLC KIM NIEDING 901 EAST CARY ST 11TH FLOOR RICHMOND VA 23219 DESJARDINS SECURITIES INC./CDS** ATTN: REORG DEPARTMENT 1 COMPLEXE DESJARDINS C.P. 34, SUCC ESJARDINS MONTREAL QC H5B 1E4 CANADA DESJARDINS SECURITIES INC./CDS** ATTN: REORG DEPT-MTL1060-1ER-E 1060 UNIVERSITY STREET SUITE 101 MONTREAL QC H3B 5L7 CANADA 2, COMPLEXE DESJARDINS DESJARDINS SECURITIES INC./CDS** CORPORATE ACTIONS VALEURS MOBILIARES DESJARDINS TOUR EST NIVEAU 62, E1-22 MONTREAL QC H5B 1J2 CANADA DESJARDINS SECURITIES INC./CDS** VERONIQUE LEMIEUX 1060 UNIVERSITY STREET SUITE 101 MONTREAL PQ H5B 5L7 CANADA DEUTSCHE BANK AG NY/CEDEAR JOHN BINDER VICE PRESIDENT 100 PLAZA ONE 2ND FLOOR JERSEY CITY NJ 07311 DEUTSCHE BANK AG NY/US CUSTODY JOHN BINDER VICE PRESIDENT 100 PLAZA ONE 2ND FLOOR JERSEY CITY NJ 07311 DEUTSCHE BANK SECURITIES INC. DB SERVICES NEW JERSEY INC. ERIC HERBST 5201 GATE PARKWAY JACKSONVILLE FL 32256 DEUTSCHE BANK SECURITIES INC. SARA BATTEN 5022 GATE PARKWAY SUITE 100 JACKSONVILLE FL 32256 E*TRADE CLEARING LLC C/O BROADRIDGE ATTN: CORPORATE ACTIONS DEPT. 2 JOURNAL SQUARE PLAZA 5TH FLOOR JERSEY CITY NJ 07306 E*TRADE CLEARING LLC JOHN ROSENBACH 1271 AVENUE OF THE AMERICAS 14TH FLOOR NEW YORK NY 10020 E*TRADE CLEARING LLC VICTOR LAU 34 EXCHANGE PLACE PLAZA II JERSEY CITY NJ 07311 EDWARD D. JONES & CO. DEREK ADAMS 12555 MANCHESTER ROAD ST LOUIS MO 63131 MARYLAND EDWARD D. JONES & CO. ELIZABETH ROLWES CORPORATE ACTIONS 201 PROGRESS PARKWAY HEIGHTS MO 63043-3042 MARYLAND EDWARD D. JONES & CO. ELIZABETH ROLWES 201 PROGRESS PARKWAY HEIGHTS MO 63043-3042 MARYLAND EDWARD JONES/CDS** CORPORATE ACTIONS 201 PROGRESS PARKWAY HEIGHTS MO 63043 EDWARD JONES/CDS** DIANE YOUNG 1255 MANCHESTER ROAD ST LOUIS MO 63141 ELECTRONIC TRANSACTION CLEARING, INC KEVIN MURPHY 660 S. FIGUEROA STREET SUITE 1450 LOS ANGELES CA 90017 ELECTRONIC TRANSACTION CLEARING, INC. KEVIN MURPHY 660 S. FIGUEROA STREET SUITE 1450 LOS ANGELES CA 90017 FIDELITY CLEARING CANADA ULC/CDS** ATTN: CORPORATE ACTIONS 245 SUMMER STREET MAILZONE V5A BOSTON MA 02210 FIDELITY CLEARING CANADA ULC/CDS** ATTN: JOHN SPURWAY 245 SUMMER STREET MAILZONE V5A BOSTON MA 02210 483 BAY STREET, SOUTH FIDELITY CLEARING CANADA ULC/CDS** CAROL ANDERSON OPERATIONS MANAGER TOWER SUITE 200 TORONTO ON M5G 2N7 CANADA 483 BAY STREET, SOUTH FIDELITY CLEARING CANADA ULC/CDS** CORP ACTION CAROL ANDERSON TOWER SUITE 200 TORONTO ON M5G 2N7 CANADA FIDELITY CLEARING CANADA ULC/CDS** LINDA SARGEANT OPERATIONS MANAGER 401 BAY STREET SUITE 2910 TORONTO ON M5H 2Y4 CANADA FIDUCIARY SSB CORPORATE ACTIONS 1776 HERITAGE DRIVE 5TH FLOOR QUINCY MA 02171 FIDUCIARY SSB STEPHEN M. MORAN 225 FRANKLIN STREET MAO-3 BOSTON MA 02110 FIDUCIARY TRUST COMPANY BRAD FINNIGAN 175 FEDERAL STREET BOSTON MA 02110 FIDUCIARY TRUST COMPANY OF BOSTON BRAD FINNIGAN 175 FEDERAL STREET BOSTON MA 02110 FIFTH THIRD BANK LANCE WELLS MANAGER 5001 KINGSLEY DRIVE MAIL DROP 1MOB2D CINCINNATI OH 45227 FIFTH THIRD BANK LANCE WELLS CORP ACTIONS 5050 KINGSLEY DRIVE MAIL DROP 1MOB2D CINCINNATI OH 45227 FIFTH THIRD BANK LANCE WELLS CORP ACTIONS 5001 KINGSLEY DRIVE MAIL DROP 1MOB2D CINCINNATI OH 45227 FIRST CLEARING, LLC CORPORATE ACTIONS 2801 MARKET STREET H0006-09B ST. LOUIS MO 63103 FOLIO INVESTMENTS, INC. ASHLEY THEOBALD MANAGER 8180 GREENSBORO DRIVE 8TH FLOOR MCLEAN VA 22102 FOLIOFN INVESTMENTS, INC. ASHLEY THEOBALD MANAGER 8180 GREENSBORO DRIVE 8TH FLOOR MCLEAN VA 22102 GLENMEDE TRUST COMPANY, N.A. (THE) DARLENE WARREN ONE LIBERTY PLACE SUITE 1200 1650 MARKET STREET PHILADELPHIA PA 19103 GMP SECURITIES L.P./CDS** MARINO MEGGETTO 145 KING STREET WEST SUITE 300 TORONTO ON M5H 1J8 CANADA GOLDMAN SACHS & CO. LLC PROXY HOTLINE 1 30 HUDSON STREET PROXY DEPARTMENT JERSEY CITY NJ 07302 GOLDMAN SACHS BANK USA PATRICIA BALDWIN ONE NEW YORK PLAZA 45TH FLOOR NEW YORK NY 10004 GOLDMAN SACHS INTERNATIONAL ASSET SERVICING 30 HUDSON STREET PROXY DEPARTMENT JERSEY CITY NJ 07302 GOLDMAN, SACHS & CO. ATTN: STEVE BERRIOS - CORPORATE ACTIONS 100 BURMA ROAD JERSEY CITY NJ 07305 GOLDMAN, SACHS & CO. PROXY HOTLINE 1 30 HUDSON STREET PROXY DEPARTMENT JERSEY CITY NJ 07302 HILLTOP SECURITIES INC. ATTN: BONNIE ALLEN 1201 ELM STREET SUITE 3500 DALLAS TX 75270

In re: Valaris plc, et al. Case No. 20-34114 (MI) Page 2 of 6 Case 20-34114 Document 947 Filed in TXSB on 01/12/21 Page 51 of 58

Exhibit D Served Via First-Class Mail

Name Attention Address 1 Address 2 Address 3 City State Zip Country HILLTOP SECURITIES INC. ATTN: BONNIE ALLEN, CORPORATE ACTIONS 1201 ELM STREET SUITE 3500 DALLAS TX 75270-2180 HILLTOP SECURITIES INC. ATTN: CORPORATE ACTIONS 1201 ELM STREET SUITE 3500 DALLAS TX 75270 HILLTOP SECURITIES INC. RHONDA JACKSON 1201 ELM STREET SUITE 3500 DALLAS TX 75270 HRT FINANCIAL LLC CORPORATE ACTIONS 32 OLD SLIP 30TH FLOOR NEW YORK NY 10005 HSBC BANK USA, NA/CLEARING CORPORATE ACTIONS HOWARD DASH 452 5TH AVENUE NEW YORK NY 10018 HSBC BANK USA, NA/CLEARING LEON SCHNITZPAHN ONE HANSON PLACE LOWER LEVEL BROOKLYN NY 11243 HSBC BANK USA, NA/HSBC CUSTODY & CLEARING SERVICES FOR STOCK CORPORATE ACTIONS ONE HANSON PLACE BROOKLYN NY 11243 INGALLS & SNYDER, LLC JOSEPH DI BUONO 61 BROADWAY 31ST FLOOR NEW YORK NY 10006 INTERACTIVE BROKERS RETAIL EQUITY CL KARIN MCCARTHY 8 GREENWICH OFFICE PARK GREENWICH CT 06831 INTERACTIVE BROKERS RETAIL EQUITY CLEARING KARIN MCCARTHY 8 GREENWICH OFFICE PARK GREENWICH CT 06831 J.P. MORGAN CLEARING CORP. ATTN: CORPORATE ACTIONS 14201 DALLAS PARKWAY 12TH FLOOR DALLAS TX 75254 J.P. MORGAN CLEARING CORP. JOHN FAY 500 STANTON CHRISTIANA ROAD OPS 4, FLOOR 03 NCC5 NEWARK DE 19713-2107 J.P. MORGAN CLEARING CORP. MARCIN BIEGANSKI 14201 DALLAS PARKWAY, 12TH FL DALLAS TX 75254 J.P. MORGAN SECURITIES LLC MICHAEL PELLEGRINO 500 STANTON CHRISTIANA ROAD CORP ACTIONS 3RD FL NEWARK DE 19713-2107 JANNEY MONTGOMERY SCOTT LLC ATTN: BRENDAI KIRBY 1717 ARCH STREET 19TH FLOOR PHILADELPHIA PA 19103 JANNEY MONTGOMERY SCOTT LLC ATTN: CORPORATE ACTIONS DEPARTMENT 1717 ARCH STREET, 19TH FLOOR PHILADELPHIA PA 19103 JANNEY MONTGOMERY SCOTT LLC ATTN: ZACHARY SCHWARZ 1717 ARCH STREET 19TH FLOOR PHILADELPHIA PA 19103

JANNEY MONTGOMERY SCOTT LLC MARK F. GRESS C/O MEDIANT COMMUNICATIONS INC. 200 REGENCY FOREST DRIVE CARY NC 27518 JANNEY MONTGOMERY SCOTT LLC REGINA LUTZ 1801 MARKET STREET, 9TH FLOOR PHILADEPHIA PA 19103-1675 JEFFERIES LLC ROBERT MARANZANO 34 EXCHANGE PL JERSEY CITY NJ 07311 JPMORGAN CHASE BANK JP MORGAN PROPRIETARY ASSET ACCOUNT NORE SCARLETT - ADMINISTRATOR 4 NEW YORK PLAZA 11TH FLOOR NEW YORK NY 10004 DEUTSCHE BANK AG (LONDON BRANCH) MARCIN CORPORATE ACTIONS JPMORGAN CHASE BANK NA/DBTC AMERICAS BIEGANSKI ASSOCIATE 14201 DALLAS PKWY, 12TH FL DEPT DALLAS TX 75254 CORPORATE ACTIONS JPMORGAN CHASE BANK NA/DBTC AMERICAS MARCIN BIEGANSKI ASSOCIATE 14201 DALLAS PKWY, 12TH FL DEPT DALLAS TX 75254 JPMORGAN CHASE BANK, N.A./CUSTODIAL TRUST COMPANY CORPORATE ACTIONS DEPT 14201 DALLAS PARKWAY, 12TH FL DALLAS TX 75254 JPMORGAN CHASE BANK, N.A./CUSTODIAL TRUST 500 STANTON CHRISTIANA COMPANY JOHN P FAY CORP ACTIONS ROAD, OPS 4 FLOOR: 03 NEWARK DE 19713-2107 500 STANTON CHRISTIANA JPMORGAN CHASE BANK, NATIONAL ASSOCI SACHIN GOYAL ASSOCIATE ROAD, OPS 4 FLOOR 02 NEWARK DE 19713-2107 FLOOR 12 - CORP JPMORGAN CHASE BANK, NATIONAL ASSOCIATION MARCIN BIEGANSKI ASSOCIATE 14201 DALLAS PKWY ACTIONS DEPT DALLAS TX 75254 JPMORGAN CHASE BANK, NATIONAL ASSOCIATION SACHIN GOYAL 500 STANTON CHRISTIANA ROAD OPS 4, FLOOR 02 NEWARK DE 19713-2107 FLOOR 12 - CORP ACTIONS JPMORGAN CHASE BANK/EUROCLEAR BANK CORPORATE ACTIONS 14201 DALLAS PKWY DEPT DALLAS TX 75254 500 STANTON CHRISTIANA JPMORGAN CHASE BANK/EUROCLEAR BANK CORPORATE ACTIONS SACHIN GOYAL ROAD OPS 4, FLOOR 02 NEWARK DE 19713-2107 KEYBANK NATIONAL ASSOCIATION RAYMOND HANNAN 4900 TIEDEMAN ROAD OH-01-49-0240 BROOKLYN OH 44144 LAURENTIAN BANK OF CANADA/CDS** FRANCESCA MAIORINO 1981 MCGILL COLLEGE AVE SUITE 100 MONTREAL QC BCAH3A 3K3 CANADA LAURENTIAN BANK OF CANADA/CDS** FRANCESCA MAIORINO 1981 MCGILL COLLEGE AVE SUITE 100 MONTREAL QUEB EBCAH3A 3K3 CANADA LEK SECURITIES CORPORATION CORPORATE ACTIONS ONE LIBERTY PLAZA 52ND FLOOR NEW YORK NY 10006 LEK SECURITIES CORPORATION CORPORATE ACTIONS DANIEL HANUKA 140 BROADWAY 29TH FLOOR NEW YORK NY 10005 LEK SECURITIES CORPORATION DANIEL HANUKA 140 BROADWAY 29TH FLOOR NEW YORK NY 10005 LPL FINANCIAL CORPORATION CORPORATE ACTIONS KRISTIN KENNEDY 9785 TOWNE CENTRE DRIVE SAN DIEGO CA 92121-1968 LPL FINANCIAL CORPORATION CORPORATE ACTIONS JACQUI TEAGUE ; KRISTIN KENNEDY 1055 LPL WAY FORT MILL SC 29715 COMMERCE COURT MACKIE RESEARCH CAPITAL CORPORATION/ TONY RODRIGUES SUPERVISOR 199 BAY STREET WEST, SUITE 4600 TORONTO ON M5L 1G2 CANADA COMMERCE COURT WEST, MACKIE RESEARCH CAPITAL CORPORATION/CDS** ATTN: CORPORATE ACTIONS 199 BAY STREET SUITE 4600 TORONTO ON M5L 1G2 CANADA COMMERCE COURT WEST, MACKIE RESEARCH CAPITAL CORPORATION/CDS** ATTN: VISHNU SANTHAKUMAR 199 BAY STREET SUITE 4600 TORONTO ON M5L 1G2 CANADA COMMERCE COURT MACKIE RESEARCH CAPITAL CORPORATION/CDS** TONY RODRIGUES SUPERVISOR 199 BAY STREET WEST, SUITE 4600 TORONTO ON M5L 1G2 CANADA MANUFACTURERS AND TRADERS TRUST COMPANY TONY LAGAMBINA ONE M&T PLAZA-8TH FLOOR BUFFALO NY 14203

MANULIFE SECURITIES INCORPORATED/CDS JOSEPH CHAU MANAGER 85 RICHMOND STREET WEST TORONTO ONTARON 500000 CANADA

MANULIFE SECURITIES INCORPORATED/CDS** JOSEPH CHAU MANAGER 85 RICHMOND STREET WEST TORONTO ON M5H2C9 CANADA MANULIFE SECURITIES INCORPORATED/CDS** SECURITIES OPERATIONS PO BOX 1700 RPO LAKESHORE WEST OAKVILLE ON L6K 0G7 CANADA MARSCO INVESTMENT CORPORATION MARK KADISON 101 EISENHOWER PARKWAY ROSELAND NJ 07068 MERRILL LYNCH PIERCE FENNER & SMITH CHRIS WIEGAND VICE PRESIDENT 4804 DEAR LAKE DR E JACKSONVILLE FL 32246 MERRILL LYNCH PIERCE FENNER & SMITH DTC 8862 EARL WEEKS 4804 DEERLAKE DR. E. JACKSONVILLE FL 32246 MERRILL LYNCH PIERCE FENNER & SMITH FIXED INCOME EARL WEEKS 4804 DEAR LAKE DR E JACKSONVILLE FL 32246 MERRILL LYNCH, PIERCE FENNER & SMITH EARL WEEKS ATTN: CORPORATE ACTIONS 4804 DEER LAKE DR. E. JACKSONVILLE FL 32246 MERRILL LYNCH, PIERCE, FENNER & SMITH INCORPORATED EARL WEEKS 4804 DEAR LAKE DR E JACKSONVILLE FL 32246

MERRILL LYNCH, PIERCE, FENNER & SMITH CHRISTINE PEARSON RAYMOND JAMES & ASSOCIATES, INC./RAY P.O. BOX 14407 ST. PETERSBURG FL 33733 MERRILL LYNCH, PIERCE, FENNER & SMITH EARL WEEKS 4804 DEAR LAKE DR E JACKSONVILLE FL 32246 MERRILL LYNCH, PIERCE, FENNER & SMITH INCORPORATED/671 MLPF& CORPORATE ACTIONS 4804 DEERLAKE DR. E. JACKSONVILLE FL 32246 1221 AVENUE OF THE MITSUBISHI UFJ TRUST & BANKING CORPO EDWARD CAPLETTE VICE PRESIDENT AMERICAS 10TH FLOOR NEW YORK NY 10022

In re: Valaris plc, et al. Case No. 20-34114 (MI) Page 3 of 6 Case 20-34114 Document 947 Filed in TXSB on 01/12/21 Page 52 of 58

Exhibit D Served Via First-Class Mail

Name Attention Address 1 Address 2 Address 3 City State Zip Country MITSUBISHI UFJ TRUST & BANKING CORPORATION, NEW YORK BRANCH RICHARD WENSKOSKI 420 FIFTH AVENUE 6TH FLOOR NEW YORK NY 10018 MIZUHO BANK (USA) ROBERT DIMICK 135 WEST 50TH STREET 16TH FLOOR NEW YORK NY 10020 MIZUHO TRUST & BANKING CO. (USA) ROBERT DIMICK 135 WEST 50TH STREET 16TH FLOOR NEW YORK NY 10020 MORGAN STANLEY & CO. INTERNATIONAL P DAN SPADACCINI 901 SOUTH BOND ST 6TH FL BALTIMORE MD 21231 MORGAN STANLEY & CO. LLC CORP ACTIONS 1300 THAMES STREET 7TH FLOOR BALTIMORE MD 21231 MORGAN STANLEY & CO. LLC MANSUR PRESIDENT 1300 THAMES STREET 5TH FL BALTIMORE MD 21231 MORGAN STANLEY & CO. LLC MICHELLE FORD 901 SOUTH BOND ST 6TH FL BALTIMORE MD 21231 MORGAN STANLEY & CO. LLC/INTERNATIONAL PLC CORP ACTIONS 1300 THAMES STREET 7TH FLOOR BALTIMORE MD 21231 MORGAN STANLEY & CO. LLC/INTERNATIONAL PLC CORPORATE ACTIONS 901 SOUTH BOND ST 6TH FL BALTIMORE MD 21231 MORGAN STANLEY SMITH BARNEY LLC JOHN BARRY 1300 THAMES ST 6TH FLOOR BALTIMORE MD 21231 NATIONAL FINANCIAL SERVICES LLC CORP ACTIONS 200 SEAPORT BOULEVARD, Z1B BOSTON MA 02210 NATIONAL FINANCIAL SERVICES LLC JOANNE PADARATHSIGN 499 WASHINGTON BLVD JERSEY CITY NJ 07310 NATIONAL FINANCIAL SERVICES LLC PETER CLOSS 499 WASHINGTON BLVD. JERSEY CITY NJ 07310 1010 RUE DE LA NBCN INC./CDS** ANNA MEDEIROS CORPORATE ACTIONS GAUCHETIERE ST WEST SUITE 1925 MONTREAL QC H3B 5J2 CANADA NOMURA SECURITIES INTERNATIONAL, INC. ADRIAN ROCCO 309 WEST 49TH STREET 10TH FLOOR NEW YORK NY 10019-1774 NOMURA SECURITIES INTERNATIONAL, INC. C/O ADP PROXY SERVICES ISSUER SERVICES 51 MERCEDES WAY EDGEWOOD NY 11717 NOMURA SECURITIES INTERNATIONAL, INC. ISSUER SERVICES C/O ADP PROXY SERVICES 51 MERCEDES WAY EDGEWOOD NY 11717 NORTH TOWER 6TH FLOOR 200 BAY ST ROYAL BK PLAZA TORONTO ONTA RM5J 2W7 CANADA ODLUM BROWN LIMITED/CDS** RON RAK SUPERVISOR 250 HOWE STREET SUITE 1100 VANCOUVER V6C 3SBC CANADA OPPENHEIMER & CO. INC. ATTN: CORPORATE ACTIONS 85 BROAD STREET NEW YORK NY 10004 OPPENHEIMER & CO. INC. ATTN: FRAN BANSON 85 BROAD STREET NEW YORK NY 10004 OPPENHEIMER & CO. INC. ATTN: SUSAN STOIA 85 BROAD STREET NEW YORK NY 10004 OPPENHEIMER & CO. INC. OSCAR MAZARIO 85 BROAD STREET NEW YORK NY 10004 PENSCO TRUST COMPANY ATTN: CORPORATE ACTIONS 1560 BROADWAY STREET SUITE 400 DENVER CO 80202 PENSCO TRUST COMPANY ATTN: PETAL YOUNG 1560 BROADWAY STREET SUITE 400 DENVER CO 80202 PENSCO TRUST COMPANY LLC HOLLY NICKERSON SUPERVISOR 560 MISSION STREET SUITE 1300 SAN FRANCISCO CA 94105 PERSHING LLC ATTN: REGAN PALMER CORPORATE ACTIONS ONE PERSHING PLAZA 10TH FLOOR JERSEY CITY NJ 07399 PERSHING LLC JOSEPH LAVARA ONE PERSHING PLAZA JERSEY CITY NJ 07399 SUITE 3050, CHICAGO BOARD PHILLIP CAPITAL INC. ATTN: CORPORATE ACTIONS 141 W JACKSON BLVD OF TRADE BUILDING CHICAGO IL 60604 PI FINANCIAL CORP./CDS** ROB MCNEIL 666 BURRARD STREET SUITE 1900 VANCOUVER V6C 3NBC CANADA PNC BANK, NATIONAL ASSOCIATION JUANITA NICHOLS 8800 TINICUM BLVD MAILSTOP F6-F266-02-2 PHILADELPHIA PA 19153 QUESTRADE INC./CDS** CORPORATE ACTIONS 5650 YONGE STREET SUITE 1700 TORONTO ON M2M 4G3 CANADA

RAYMOND JAMES & ASSOCIATES, INC. ATTN: ELAINE MULLEN CORPORATE ACTIONS 880 CARILLON PARKWAY ST. PETERSBURG FL 33716 SAIT RAYMOND JAMES & ASSOCIATES, INC. ROBERTA GREEN 880 CARILION PARKWAY PETERSBURG FL 33716 RAYMOND JAMES & ASSOCIATES, INC./RAYMOND JAMES TRUST COMPANY CHRISTINE PEARSON P.O. BOX 14407 ST. PETERSBURG FL 33733

RAYMOND JAMES LTD./CDS** CORPORATE ACTIONS PO BOX 23558 ST PETERSBURG FL 33742-3558 RBC CAPITAL MARKETS, LLC ATTN: REORG DEPARTMENT 60 S 6TH ST MINNEAPOLIS MN 55402 RBC CAPITAL MARKETS, LLC SHANNON JONES 60 S 6TH ST - P09 MINNEAPOLIS MN 55402-4400 RBC CAPITAL MARKETS, LLC STEVE SCHAFER SR ASSOCIATE 60 S 6TH ST - P09 MINNEAPOLIS MN 55402-4400 ROYAL BANK PLAZA NORTH RBC DOMINION SECURITIES INC./CDS** KAREN OLIVERES 200 BAY STREET, 6TH FLOOR TOWER TORONTO ON M5J 2W7 CANADA RBC DOMINION SECURITIES INC./CDS** PETER DRUMM 200 BAY ST ROYAL BK PLAZA NORTH TOWER 6TH FLOOR TORONTO ON M5J 2W7 CANADA 500 NORTHPARK RELIANCE TRUST COMPANY/FIS TRUSTDESK MKE CORPORATE ACTIONS JULIE MCGUINESS 1100 ABERNATHY ROAD BUILDING SUITE 400 ATLANTA GA 30328 RELIANCE TRUST COMPANY/SWMS1 CORPORATE ACTIONS 1100 ABERNATHY ROAD STE 400 ATLANTA GA 30328 RELIANCE TRUST COMPANY/SWMS1 TONIE MONTGOMERY 1100 ABERNATHY ROAD STE 400 ATLANTA GA 30328 RELIANCE TRUST COMPANY/SWMS2 TONIE MONTGOMERY 1100 ABERNATHY ROAD SUITE 400 ATLANTA GA 30328 ROBERT W. BAIRD & CO. INCORPORATED JAN SUDFELD 777 E. WISCONSIN AVENUE 19TH FLOOR MILWAUKEE WI 53202 ROBINHOOD SECURITIES, LLC CORPORATE ACTIONS 85 WILLOW ROAD MENLO PARK CA 94025

ROBINHOOD SECURITIES, LLC CORPORATE ACTIONS DAWN PAGLIARO 500 COLONIAL CENTER PKWY #100 LAKE MARY FL 32746 SAFRA SECURITIES LLC CORPORATE ACTIONS 546 FIFTH AVENUE NEW YORK NY 10036 SANFORD C. BERNSTEIN & CO., LLC ANITA BACTAWAR 1 NORTH LEXINGTION AVE C/O RIDGE WHITE PLAINS NY 10601 SCOTIA CAPITAL INC./CDS** CORPORATE ACTIONS LUISA DOMINGUES 40 KING STREET W TORONTO ON M5H1H1 CANADA SCOTIA CAPITAL INC./CDS** LILIAN NIE CORPORATE ACTIONS 40 KING STREET W 23RD FLOOR TORONTO ON M5H1H1 CANADA SEI PRIVATE TRUST COMPANY ERIC GREENE ONE FREEDOM VALLEY DRIVE OAKS PA 19456 SEI PRIVATE TRUST COMPANY/C/O GWP DIANA MASON CORPORATE ACTIONS 1 FREEDOM VALLEY DRIVE OAKS PA 19456 SEI PRIVATE TRUST COMPANY/C/O GWP ERIC GREENE ONE FREEDOM VALLEY DRIVE OAKS PA 19456 SG AMERICAS SECURITIES, LLC CHARLES HUGHES 480 WASHINGTON BLVD JERSEY CITY NJ 07310 SG AMERICAS SECURITIES, LLC PAUL MITSAKOS 480 WASHINGTON BLVD. JERSEY CITY NJ 07310 SSB - BLACKROCK INSTITUTIONAL TRUST LINDA SELBACH 45 FREMONT STREET SAN FRANCISCO CA 94120-7101 SSB - BLACKROCK INSTITUTIONAL TRUST TRINA ESTREMERA 1776 HERITAGE DRIVE NORTH QUINCY MA 02171

SSB - TRUST CUSTODY ED CHANEY VICE PRESIDENT 1200 CROWN COLONY DRIVE QUINCY MA 02169 STATE STREET BANK & TRUST COMPANY CORP ACTION 225 FRANKLIN STREET MAO-3 BOSTON MA 02110 STATE STREET BANK & TRUST COMPANY PROXY SERVICES 1776 HERITAGE DRIVE NORTH QUINCY MA 02171 STATE STREET BANK AND TRUST COMPANY CHRISTINE SULLIVAN 1776 HERITAGE DR. NORTH QUINCY MA 02171 STATE STREET BANK AND TRUST COMPANY DEUTSCHE BANK FRANKFURT KAREN T JOHNDROW 1776 HERITAGE DRIVE NORTH QUINCY MA 02171 STATE STREET BANK AND TRUST COMPANY PROXY SERVICES CHRISTINE SULLIVAN; JERRY PARRILLA 1776 HERITAGE DR. NORTH QUINCY MA 02171

In re: Valaris plc, et al. Case No. 20-34114 (MI) Page 4 of 6 Case 20-34114 Document 947 Filed in TXSB on 01/12/21 Page 53 of 58

Exhibit D Served Via First-Class Mail

Name Attention Address 1 Address 2 Address 3 City State Zip Country STATE STREET BANK AND TRUST COMPANY/ KAREN T JOHNDROW 1776 HERITAGE DRIVE NORTH QUINCY MA 02171

STATE STREET CORP ON BEHALF OF HSBC WEALTH MANAGER SERVICES CORP ACTIONS 1200 CROWN COLONY DRIVE QUINCY MA 02169 STATE STREET TRUST T479 GLOBAL CORPORATE ACTIONS PO BOX 1631 BOSTON MA 02105-1631 STERNE, AGEE & LEACH, INC. ATTN: JUSTIN WOODHAM CORPORATE ACTIONS 2 PERIMETER PARK SOUTH SUITE 100W BIRMINGHAM AL 35243 STERNE, AGEE & LEACH, INC. KEN SIMPSON, JAMES MEZRANO 2 PERIMETER PARK SUITE 100W BIRMINGHAM AL 35209 STIFEL, NICOLAUS & COMPANY, INCORPORATED 501 N BROADWAY ONE FINANCIAL PLAZA ST LOUIS MO 63102 STIFEL, NICOLAUS & COMPANY, INCORPORATED ATTN: CHRIS WIEGAND 501 N BROADWAY ST. LOUIS MO 63102 STIFEL, NICOLAUS & COMPANY, INCORPORATED ATTN: TINA SCHWEITZER ONE FINANCIAL PLAZA 501 N BROADWAY ST. LOUIS MO 63102 STIFEL, NICOLAUS & COMPANY, INCORPORATED ATTN: ZACHARY J. RESMANN 501 N BROADWAY ST. LOUIS MO 63102 STIFEL, NICOLAUS & COMPANY, INCORPORATED C/O MEDIAN COMMUNICATIONS 200 REGENCY FOREST DRIVE CARY NC 27518 STOCKCROSS FINANCIAL SERVICES, INC. ATTN: CORPORATE ACTIONS, LORETTA RACER 1900 ST. JAMES PLACE #120 HOUSTON TX 77056 STOCKCROSS FINANCIAL SERVICES, INC. ATTN: KIMBERLEY DEHN 1900 ST. JAMES PLACE #120 HOUSTON TX 77056 STOCKCROSS FINANCIAL SERVICES, INC. ATTN: LISA BRUNSON 9464 WILSHIRE BLVD BEVERLY HILLS CA 90212 STOCKCROSS FINANCIAL SERVICES, INC. CORPORATE ACTIONS 9464 WILSHIRE BLVD. BEVERLY HILLS CA 90212 STOCKCROSS FINANCIAL SERVICES, INC. DIANE TOBEY 77 SUMMER STREET BOSTON MA 02110 SUMITOMO MITSUI TRUST BANK (U.S.A.) BETH CUMMINGS 111 RIVER STREET HOBOKEN NJ 07030 SUMITOMO MITSUI TRUST BANK (U.S.A.) LIMITED BETH CUMMINGS 111 RIVER STREET HOBOKEN NJ 07030 TD AMERITRADE CLEARING, INC. ATTN: CORP ACTIONS SUZANNE BRODD 200 S. 108TH AVENUE OMAHA NE 68154 TD AMERITRADE CLEARING, INC. KEVIN STRINE 4211 S. 102ND STREET OMAHA NE 68127 TD AMERITRADE CLEARING, INC. MANDI FOSTER 1005 N. AMERITRADE PLACE BELLEVUE NE 68005 TD WATERHOUSE CANADA INC./CDS** YOUSUF AHMED 77 BLOOR STREET WEST 3RD FLOOR TORONTO ON M4Y 2T1 CANADA TEXAS TREASURY SAFEKEEPING TRUST COM JANIE DOMINGUEZ 208 E. 10TH STREET ROOM 410 AUSTIN TX 78701 TEXAS TREASURY SAFEKEEPING TRUST COMPANY JANIE DOMINGUEZ 208 E. 10TH STREET ROOM 410 AUSTIN TX 78701 THE BANK OF NEW YORK MELLON CHARLES STANLEYAND COMPANY, LIMITED MICHAEL KANIA - VICE PRESIDENT 525 WILLIAM PENN PLACE PITTSBURGH PA 15259 THE BANK OF NEW YORK MELLON CORP ACTIONS 525 WILLIAM PENN PLACE SUITE 153-0400 PITTSBURGH PA 15259 THE BANK OF NEW YORK MELLON JENNIFER MAY 525 WILLIAM PENN PLACE SUITE 153-0400 PITTSBURGH PA 15259 MELLON TRST OF NEW ENGLAND, NATIONAL THE BANK OF NEW YORK MELLON ASSOC. CORP ACTIONS 525 WILLIAM PENN PLACE SUITE 153-0400 PITTSBURGH PA 15259 THE BANK OF NEW YORK MELLON/MELLON T SEAN GARRISON 525 WILLIAM PENN PLACE SUITE 153-0400 PITTSBURGH PA 15259 THE BANK OF NEW YORK MELLON/MID CAP SPDRS CORP ACTIONS VICE PRESIDENT 525 WILLIAM PENN PLACE PITTSBURGH PA 15259 THE HUNTINGTON NATIONAL BANK CORPORATE ACTIONS DAVID GUNNING 5555 CLEVELAND AVE. GW4E62 COLUMBUS OH 43231 THE HUNTINGTON NATIONAL BANK DAVID GUNNING 5555 CLEVELAND AVE. GW4E62 COLUMBUS OH 43231 THE HUNTINGTON NATIONAL BANK PAULA FLETCHER 7 EASTON OVAL COLUMBUS OH 43219 THE NORTHERN TRUST COMPANY ANDREW LUSSEN ATTN: CAPITAL STRUCTURES-C1N 801 S CANAL STREET CHICAGO IL 60607 THE NORTHERN TRUST COMPANY ATTN: CORPORATE ACTIONS RYAN CHISLETT 801 S CANAL STREET CHICAGO IL 60607 ATTN: CAPITAL THE NORTHERN TRUST COMPANY RYAN CHISLETT TEAM LEADER 801 S CANAL STREET STRUCTURES-C1N CHICAGO IL 60607 TRADESTATION SECURITIES, INC. ATTN: ANDREA AUGUSTIN CORPORATE ACTIONS 8050 SW 10TH ST PLANTATION FL 33324 TRADESTATION SECURITIES, INC. ATTN: DAVID BIALER 8050 SW 10TH STREET SUITE 400 PLANTATION FL 33324 U.S. BANCORP INVESTMENTS, INC. ATTN: CHERICE TVEIT 60 LIVINGSTON AVE ST. PAUL MN 55107 U.S. BANCORP INVESTMENTS, INC. ATTN: REORG DEPARTMENT 60 LIVINGSTON AVE ST. PAUL MN 55107 U.S. BANCORP INVESTMENTS, INC. KEVIN BROWN ASSISTANT VICE PRESIDENT 60 LIVINGSTON AVE ST. PAUL MN 55107-1419 U.S. BANK N.A. STEPHANIE KAPTA 1555 N RIVERCENTER DRIVE SUITE 302 MILWAUKEE WI 53212 1000 HARBOR BLVD - 5TH UBS AG STAMFORD BRANCH AS CUSTODIAN FOR UBSAG LONDON BRANCH GREGORY CONTALDI - DIRECTOR FLOOR WEEHAWKEN NJ 07086 1000 HARBOR BLVD - 5TH UBS AG STAMFORD BRANCH/AS CUSTODIAN GREGORY CONTALDI DIRECTOR FLOOR WEENHAWKEN NJ 07086 UBS FINANCIAL SERVICES INC. ATTN: CORPORATE ACTIONS 1000 HARBOR DRIVE WEEHAWKEN NJ 07086 UBS FINANCIAL SERVICES INC. JANE FLOOD 1000 HARBOR BLVD WEEHAWKEN NJ 07086 UBS SECURITIES LLC GREGORY CONTALDI 1000 HARBOR BLVD - 5TH FLOOR WEENHAWKEN NJ 07086 1000 HARBOR BLVD - 5TH UBS SECURITIES LLC GREGORY CONTALDI DIRECTOR FLOOR WEENHAWKEN NJ 07086 UBS SECURITIES LLC/CMO SCOTT HARRIS 480 WASHINGTON BLVD JERSEY CITY NJ 07310 UBS SECURITIES LLC/SECURITIES LENDIN GREGORY CONTALDI 480 WASHINGTON BLVD 12TH FLOOR JERSEY CITY NJ 07310 UBS SECURITIES LLC/SECURITIES LENDING GREGORY CONTALDI 480 WASHINGTON BLVD 12TH FLOOR JERSEY CITY NJ 07310 UMB BANK, NATIONAL ASSOCIATION VINCENT DUNCAN 928 GRAND BLVD KANSAS CITY MO 64133 UNION BANK & TRUST COMPANY TAMMY ENGLE PO BOX 11126 HAUPPAUGE NY 11788-0934 UNION BANK & TRUST COMPANY TAMMY ENGLE C/O PROXYTRUST PO BOX 11126 HAUPPAUGE NY 11788-0934 VANGUARD MARKETING CORPORATION PO BOX 1170 VALLEY FORGE PA 19482-1170 VANGUARD MARKETING CORPORATION 100 VANGUARD BOULEVARD MALVERN PA 19355 VANGUARD MARKETING CORPORATION ATTN: BEN BEGUIN 14321 N. NORTHSIGHT BOULEVARD SCOTTSDALE AZ 85260 VELOX CLEARING LLC 2400 E KATELLA AVE ANAHEIM CA 92806 VISION FINANCIAL MARKETS LLC ANA MARTINEZ ASSOCIATE VICE PRESIDENT 4 HIGH RIDGE PARK STAMFORD CT 06804 VISION FINANCIAL MARKETS LLC ANA MARTINEZ 120 Long Ridge Road 3 North STAMFORD CT 06902 VISION FINANCIAL MARKETS LLC ANA MARTINEZ CORPORATE ACTIONS 4 HIGH RIDGE PARK STAMFORD CT 06804 WEDBUSH SECURITIES INC. ALAN FERREIRA P.O. BOX 30014 LOS ANGELES CA 90030 WEDBUSH SECURITIES INC. DONNA WONG 1000 WILSHIRE BLVD LOS ANGELES CA 90030 WEDBUSH SECURITIES INC./P3 ALAN FERREIRA 1000 WILSHIRE BLVD SUITE #850 LOS ANGELES CA 90030 WELLS FARGO BANK, NATIONAL ASSOCIATI LORA DAHLE 550 SOUTH 4TH STREET MAC N9310-141 MINNEAPOLIS MN 55415 WELLS FARGO BANK, NATIONAL ASSOCIATION CORPORATE ACTIONS 733 MARQUETTE AVENUE-5TH FLOOR MINNEAPOLIS MN 55479 WELLS FARGO BANK, NATIONAL ASSOCIATION LORA DAHLE CORPORATE ACTIONS 550 SOUTH 4TH STREET MAC N9310-141 MINNEAPOLIS MN 55415 WELLS FARGO CLEARING SERVICES LLC MATT BUETTNER 2801 MARKET STREET H0006-09B ST. LOUIS MO 63103 1525 WEST W.T. WELLS FARGO SECURITIES, LLC ROBERT MATERA ASSISTANT VICE PRESIDENT CORP ACTIONS - NC0675 HARRIS BLVD, 1B1 CHARLOTTE NC 28262

In re: Valaris plc, et al. Case No. 20-34114 (MI) Page 5 of 6 Case 20-34114 Document 947 Filed in TXSB on 01/12/21 Page 54 of 58

Exhibit D Served Via First-Class Mail

Name Attention Address 1 Address 2 Address 3 City State Zip Country WESBANCO BANK, INC. SUSAN KOVAL ONE BANK PLAZQ WHEELING WV 26003 WILSON-DAVIS & CO., INC. BILL WALKER 236 SOUTH MAIN STREET SALT LAKE CITY UT 84101 ZIONS FNB/WESTERN NATIONAL JOHN RIZZO 1 SOUTH MAIN 17TH FLOOR SALT LAKE CITY UT 84111

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Exhibit E

Case 20-34114 Document 947 Filed in TXSB on 01/12/21 Page 56 of 58

Exhibit E Served Via Electronic Mail

Name Email AMERICAN ENTERPRISE INVESTMENT SERVICES INC. [email protected] AMERICAN ENTERPRISE INVESTMENT SERVICES INC. [email protected] AMERICAN ENTERPRISE INVESTMENT SERVICES INC. [email protected]; [email protected] AMERICAN ENTERPRISE INVESTMENT SERVICES INC. [email protected] AMERICAN ENTERPRISE INVESTMENT SERVICES INC. [email protected]; [email protected] APEX CLEARING CORPORATION [email protected]; [email protected] APEX CLEARING CORPORATION [email protected] Bank of America DTC #0773 #05198 [email protected] Bank of America DTC #0773 #05198 [email protected] Bank of America DTC #0773 #05198 [email protected] Bank of America NA/Client Assets DTC #02251 [email protected] [email protected]; [email protected]; [email protected]; BANK OF AMERICA, NA/GWIM TRUST OPERATIONS [email protected]; [email protected]; [email protected] Barclays Capital Inc. DTC #0229 [email protected] BB&T SECURITIES, LLC [email protected] BB&T SECURITIES, LLC [email protected] Bloomberg [email protected] [email protected]; [email protected]; [email protected]; BMO CAPITAL MARKETS CORP. [email protected] [email protected]; [email protected]; [email protected]; BMO NESBITT BURNS INC./CDS** [email protected] BMO Nesbitt Burns Inc./CDS** DTC# 05043 [email protected]; [email protected] BMO Nesbitt Burns Inc./CDS** DTC# 05043 [email protected] BNP PARIBAS, NEW YORK BRANCH/BNP PARIBAS PRIME [email protected] BNP PARIBAS, NEW YORK BRANCH/BNPP SA [email protected] BNP PARIBAS, NY BRANCH/ BNPP SA [email protected] [email protected]; [email protected]; [email protected]; BNY MELLON WEALTH MANAGEMENT [email protected] [email protected]; [email protected]; [email protected]; BNYMELLON/CACEIS BANK LUXEMBOURG [email protected] [email protected]; [email protected]; [email protected]; BNYMELLON/WEALTH MANAGEMENT [email protected] [email protected]; [email protected]; [email protected]; BNYMELLON/WEALTH MANAGEMENT [email protected]; [email protected] BRANCH BANKING AND TRUST COMPANY [email protected] Broadridge [email protected] Broadridge [email protected] Brown Brothers Harriman & Co. DTC #010 [email protected] Brown Brothers Harriman & Co. DTC #010 [email protected] Brown Brothers Harriman & Co. DTC #010 [email protected] Brown Brothers Harriman & Co. DTC #010 [email protected] Brown Brothers Harriman & Co. DTC #010 [email protected] Brown Brothers Harriman & Co. DTC #010 [email protected] CALDWELL TRUST COMPANY [email protected] CETERA INVESTMENT SERVICES LLC [email protected]; [email protected] Charles Schwab & Co. Inc. DTC #0164 [email protected] Charles Schwab & Co. Inc. DTC #0164 [email protected] CHARLES SCHWAB & CO., INC. [email protected]; [email protected] CIBC WORLD MARKETS INC./CDS** [email protected] [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; CITIBANK, N.A. [email protected]; [email protected]; [email protected]; Citibank, N.A. DTC #0908 [email protected] CITIGROUP GLOBAL MARKETS INC./SALOMO [email protected]

COMPUTERSHARE TRUST COMPANY, N.A./DRP [email protected]; [email protected]; [email protected] COR CLEARING LLC [email protected] COR CLEARING LLC [email protected] COR CLEARING LLC/STOCK LOAN [email protected] Credit Agricole Secs USA Inc. DTC #0651 [email protected] CREDIT SUISSE SECURITIES (USA) LLC [email protected]; [email protected]; [email protected] CREDIT SUISSE SECURITIES (USA) LLC [email protected]; [email protected] Credit Suisse Securities (USA) LLC DTC #0355 [email protected] Credit Suisse Securities (USA) LLC DTC #0355 [email protected] CREWS & ASSOCIATES, INC. [email protected] D. A. DAVIDSON & CO. [email protected]; [email protected] D. A. DAVIDSON & CO. [email protected]; [email protected]; [email protected]; [email protected] DESJARDINS SECURITIES INC./CDS** [email protected] DESJARDINS SECURITIES INC./CDS** [email protected] DESJARDINS SECURITIES INC./CDS** [email protected] DEUTSCHE BANK AG NY/US CUSTODY [email protected] Deutsche Bank Securities Inc. DTC #0573 [email protected] EDWARD D. JONES & CO. [email protected] EDWARD D. JONES & CO. [email protected]

[email protected]; [email protected]; [email protected]; EDWARD JONES/CDS** [email protected]; [email protected]; [email protected] Euroclear Bank S.A./N.V. [email protected] Euroclear Bank S.A./N.V. [email protected] [email protected]; [email protected]; [email protected]; [email protected]; FIDELITY CLEARING CANADA ULC/CDS** [email protected]; [email protected]; [email protected]; [email protected] FIDELITY CLEARING CANADA ULC/CDS** [email protected] FIFTH THIRD BANK [email protected]; [email protected]

In re: Valaris plc, et al. Case No. 20-34114 (MI) Page 1 of 3 Case 20-34114 Document 947 Filed in TXSB on 01/12/21 Page 57 of 58

Exhibit E Served Via Electronic Mail

RAYMOND JAMES & ASSOCIATES, INC./RAYMOND JAMES TRUST COMPANY [email protected] RBC CAPITAL MARKETS, LLC [email protected]; [email protected] RBC CAPITAL MARKETS, LLC [email protected] [email protected]; [email protected]; RELIANCE TRUST COMPANY/FIS TRUSTDESK MKE [email protected] RELIANCE TRUST COMPANY/SWMS1 [email protected] RELIANCE TRUST COMPANY/SWMS1 [email protected]; [email protected] RELIANCE TRUST COMPANY/SWMS2 [email protected]; [email protected] Royal Bank of Canada [email protected] SEI PV/GWP #02663 [email protected] SIS SegaInterSettle AG [email protected] SIS SegaInterSettle AG [email protected] Southwest Securities [email protected] Southwest Securities [email protected] [email protected]; [email protected]; [email protected]; STATE STREET BANK & TRUST COMPANY [email protected]; [email protected] STATE STREET BANK & TRUST COMPANY [email protected]; [email protected] State Street Bank and Trust Co DTC #0997 [email protected]

In re: Valaris plc, et al. Case No. 20-34114 (MI) Page 2 of 3 Case 20-34114 Document 947 Filed in TXSB on 01/12/21 Page 58 of 58

Exhibit E Served Via Electronic Mail

Name Email State Street Bank and Trust Co DTC #0997 [email protected] State Street Bank and Trust Co DTC #0997 [email protected] [email protected]; [email protected]; [email protected]; STATE STREET BANK AND TRUST COMPANY [email protected]; [email protected]

STIFEL, NICOLAUS & COMPANY, INCORPORATED [email protected]; [email protected]; [email protected]; [email protected]; [email protected] STOCKCROSS FINANCIAL SERVICES, INC. [email protected]; [email protected] STOCKCROSS FINANCIAL SERVICES, INC. [email protected]; [email protected] STOCKCROSS FINANCIAL SERVICES, INC. [email protected] STOCKCROSS FINANCIAL SERVICES, INC. [email protected]; [email protected]; [email protected] SUMITOMO MITSUI TRUST BANK (U.S.A.) LIMITED [email protected]

In re: Valaris plc, et al. Case No. 20-34114 (MI) Page 3 of 3