Compliance With Model Code

In accordance with the provisions of Listing Rule 15.5.1(4) Jupiter Second
Enhanced Income Trust PLC (the `Company') confirms that:

  (a)  there is no unpublished information which constitutes price sensitive
       information in respect of the Company's securities;
  (b)  the Company's net asset value per share is calculated and announced through
       a Regulated Information Service on a weekly basis;
  (c)  the Company has no reason to believe that there will be any material
       difference between the net asset value announced on 4th November 2008 (as at
       close of business on 31st October 2008) and the financial information to be
       published in the final results;
  (d)  the Company has no unquoted investments; and
  (e)  the Company announced its fourth interim dividend on 10th November and the
       Company does not have plans to pay any further dividends in respect of the year
       to 31st October 2008.

Accordingly the Company is exempt during the close period from the provisions of
the Model Code in respect of dealings by persons discharging managerial
responsibilities and purchasing its own securities.  If, in the period leading
up to the preliminary announcement of the results, the directors or the Company
come into possession of any inside information, this will be notified to a RIS
before any such transaction is undertaken.

The close period to which this relates is in respect of the year to 31st October
2008.

Enquiries:

Jenny Thompson
Company Secretary
Jupiter Asset Management Limited
[e-mail]
020-7314-5565