Transaction in Own Shares

ATLANTIS JAPAN GROWTH FUND LIMITED                       

                           ("AJGF" or the "Company")                           

 (a closed-ended investment company incorporated in Guernsey with registration 
                                 number 30709)                                 

                           Transaction in Own Shares                           

                                3 November 2014                                

The Company announces that on 31 October 2014 it issued the following ordinary
shares from Treasury:

  * 200,000 ordinary shares of no par value ("ordinary shares") in the capital
    of the Company at a price of GBP 1.2000 per Sterling share.
   
These shares were original held in Treasury and have now been reissued as
ordinary shares. In issuing these new ordinary shares the Company confirms that
they have been sold from Treasury at a discount smaller than that at which they
were bought back (calculated on a weighted average basis) and have not be sold
at a discount of more than 10 per cent. of the middle market price of new
ordinary shares at the time of sale

Following this issue of ordinary shares from treasury, the total number of
shares in issue of the Company will be as follows:

Total number of treasury shares held by Number of shares in issue less shares  
the Company                             held in treasury                       
                                                                               
2,081,686 Sterling Shares               41,729,329 Sterling Shares              

From 31 October 2014, the total number of voting rights in the Company (rounded
down to the whole number) is 41,729,329.

Enquiries:
Northern Trust International Fund Administration Services (Guernsey) Limited
Tel: [phone]