Compliance with Model Code

The Investment Company plc                           

                                (the "Company")                                

Compliance with Model Code

In accordance with the provision of Listing Rule 15.5.1 the Company is
satisfied that all inside information which the Directors and the Company may
have to 3 July 2014 has previously been notified to a Regulated Information
Service. 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:

(a) dealings by persons discharging managerial responsibilities in the Company;

(b) purchases by the Company of its own securities;

(c) issues by the Company of securities;

(d) sales 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).