Compliance with Model Code

Keystone Investment Trust plc                         

Statement re Compliance with the Model Code

Listing Rule 15.5.1 - Transactions in a close period

In accordance with LR 15.5.1(4), the Directors of Keystone Investment Trust plc
(`the Company') confirm that they are satisfied that all inside information
which the Directors and the Company have leading up to the announcement of the
annual financial results has been notified to a Regulated Information Service
and, therefore, dealings as referred to in LR 15.5.1(3) are permitted. Should
the Directors or the Company come into possession of inside information before
the annual financial results are announced this will be notified to a RIS
before any such dealings are transacted.

Invesco Asset Management Limited

Corporate Company Secretary

3 October 2011