Compliance with Model Code

Menhaden Capital 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 relating to the Company 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 final results for the year ended 31 December 2015 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 final 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 year ended 31 December 2015.

Frostrow Capital LLP

Company Secretary

13 January 2016