Compliance with Model Code

The Biotech Growth Trust PLC

3 October 2011

                  The Biotech Growth Trust PLC (the'Company')                  

           Listing Rule 15.5.1 (4) - Transactions in a Close Period            

In accordance with Listing Rule 15.5.1 (4), the Directors of the Company
confirm that they are satisfied that all inside information that the Directors
and the Company have up until the date of this notice has been notified to a
Regulated Information Service ("RIS") and that any further inside information
leading up to the announcement of the interim results for the six months to 30
September 2011 will be notified to a RIS.

The Company and persons discharging managerial responsibilities for the Company
are therefore exempt during the close period from the provisions of the Model
Code in respect of dealings in the Company's own securities. If, in the period
leading up to the announcement of the interim results, the Directors of the
Company or any person discharging managerial responsibilities come into
possession of any inside information, this will be notified to a RIS before any
such transactions are undertaken.

The close period to which this notification relates is in respect of the six
months ended 30 September 2011.

Frostrow Capital LLP

Company Secretary

3 October 2011