Derogation from Model Code

Atlantis Japan Growth Fund Ld
09 January 2008


                       Atlantis Japan Growth Fund Limited
                                ('the Company')
                                 9 January 2008


                         Derogation from the Model Code


Pursuant to Listing Rule 15.5.1 R (Compliance with the Model Code) the Company
hereby wishes to notify the market that the upcoming closed period of the
Company will commence on 25 January 2008 and is anticipated to end following the
release of the final results on or around 26 March 2008.

In accordance with Listing Rule 15.5.1 (4), the Company confirms that weekly
NAVs have been and will continue to be notified to the Exchange and that the
Directors and the Company are not in possession of any additional price
sensitive information that has not been notified to the Exchange.

Accordingly the Company will continue to adopt the Model Code during the close
period with the exception of the following activities, which maybe undertaken:
     
(a)  dealings by persons discharging managerial responsibilities in the Company;

(b)  purchases by the Company of its own securities;

(c)  sales of treasury shares for cash or transfers (except for sales and 
     transfers by the Company of treasury shares in the circumstances set out 
     in LR 12.6.2 R).


Enquiries:

Andrew Maiden
Northern Trust International Fund Administration Services (Guernsey) Limited
Trafalgar Court
Les Banques
St Peter Port
Guernsey
GY1 3QL

01481 745368


END


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