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 Half-Yearly results has been notified to a Regulated Information Service.

Kerstin Rucht

for and on behalf of

INVESCO Asset Management Limited

1 April 2009