Derogation of Model Code

Acorn Income Fund Limited
(a closed ended investment company incorporated in Guernsey with registration number 34778)

LEI 213800UAZN7G46AHQM67

Derogation of Model Code

9 January 2018

In accordance with Listing Rule 15.5.1(4), the Directors of the Company confirm that they are satisfied that all inside information, which the Directors and the Company have leading up to the announcement of the results for the year ended 31 December 2017, has previously been notified to a Regulated Information Service and, therefore, the dealings referred to in Listing Rule 15.5.1 (3) are permitted.

Accordingly, the Company will continue to adopt the Model Code during the close period, with the exception of the following activities which may be undertaken:

- dealings by persons discharging managerial responsibilities in the Company;

- purchases by the Company of its own securities;

- sale of treasury shares for cash or transfers (except for sales and transfers by the Company of treasury shares in the circumstances set out in LR 12.6.2 R).

Enquiries:

Northern Trust International Fund Administration Services (Guernsey) Limited
The Company Secretary
Trafalgar Court
Les Banques
St Peter Port
Guernsey
GY1 3QL
Tel:       [phone]