Compliance with Model Code

Keystone Investment Trust plc                         

HEADLINE: Listing Rule 15.5.1 - Transactions in a close period

In accordance with LR 15.5.1, the directors of Keystone Investment Trust plc
(`the Company') can confirm that they are satisfied that all inside information
which the directors and the Company have in leading up to the announcement of
the annual results has been notified to a Regulated Information Service.

Kerstin Rucht

for and on behalf of

Invesco Asset Management Limited

1 October 2008