Director/PDMR Shareholding

  Annex DTR3

Notification of Transactions of Directors/Persons Discharging Managerial Responsibility and Connected Persons

  All relevant boxes should be completed in block capital letters.

RUFFER INVESTMENT COMPANY LIMITED	2. State whether the notification relates to (i) a transaction notified in accordance with DTR 3.1.2 R, (ii) a disclosure made in accordance with LR 9.8.6R(1) or (iii) a disclosure made in accordance with section 793 of the Companies Act (2006). (i)
3. Name of person discharging managerial responsibilities/director ASHE WINDHAM	4. State whether notification relates to a person connected with a person discharging managerial responsibilities/director named in 3 and identify the connected person NO
5. Indicate whether the notification is in respect of a holding of the person referred to in 3 or 4 above or in respect of a non-beneficial interest1   ASHE WINDHAM	6. Description of shares (including class), debentures or derivatives or financial instruments relating to shares REDEEMABLE PARTICIPATING PREFERENCE SHARES
7. Name of registered shareholders(s) and, if more than one, the number of shares held by each of them HARGREAVES LANSDOWN SIPP – 32,000 SHARES BARCLAYS ISA – 35,000 SHARES	8. State the nature of the transaction PURCHASE
9. Number of shares, debentures or financial instruments relating to shares acquired 3,000 SIPP	10. Percentage of issued class acquired (treasury shares of that class should not be taken into account when calculating percentage) 0.0019%
11. Number of shares, debentures or financial instruments relating to shares disposed N/A	12. Percentage of issued class disposed (treasury shares of that class should not be taken into account when calculating percentage) N/A
13. Price per share or value of transaction 199.155 pence per share	14. Date and place of transaction 26 February 2016, London
15. Total holding following notification and total percentage holding following notification (any treasury shares should not be taken into account when calculating percentage) 70,000 SHARES – 0.0449%	16. Date issuer informed of transaction 26 February 2016
If a person discharging managerial responsibilities has been granted options by the issuer complete the following boxes
17. Date of grant	18. Period during which or date on which exercisable
19. Total amount paid (if any) for grant of the option	20. Description of shares or debentures involved (class and number)
21. Exercise price (if fixed at time of grant) or indication that price is to be fixed at the time of exercise	22. Total number of shares or debentures over which options held following notification
23. Any additional information	24. Name of contact and telephone number for queries

Name of authorised official of issuer responsible for making notification

Martin Bourgaize

for Northern Trust International Fund Administration Services (Guernsey) Limited 

as Company Secretary to  Ruffer Investment Company  Limited 

Tel: [phone]  Email: [e-mail]

Date of notification ____26 February 2016______________________

Notes: This form is intended for use by an issuer to make a RIS notification required by DTR 3.1.4.

(1) An issuer making a notification in respect of a transaction relating to the shares or debentures of the issuer should complete boxes 1 to 16, 23 and 24.

(2) An issuer making a notification in respect of a derivative relating the shares of the issuer should complete boxes 1 to 4, 6, 8, 13, 14, 16, 23 and 24.

(3) An issuer making a notification in respect of options granted to a director/person discharging managerial responsibilities should complete boxes 1 to 3 and 17 to 24.

(4) An issuer making a notification in respect of a financial instrument relating to the shares of the issuer (other than a debenture) should complete boxes 1 to 4, 6, 8, 9, 11, 13, 14, 16, 23 and 24.