Listing Rule 15.5.1(4)

Securities Trust of Scotland plc ("the Company) Compliance with Model Code - 1 October 2008 In accordance with Listing Rule 15.5.1(4), the Company confirms that it is satisfied that all inside information, which the Directors and the Company have, leading up to the announcement of the interim results for the six months to 30 September 2008 has been notified to a Regulatory Information Service ("RIS"). The Company is therefore exempt during the close period from the provisions of the Model Code in respect of dealings by persons discharging managerial responsibilities and purchases of its own securities. If, in the period leading up to the 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 transactions are undertaken. Tamsin Hooton Martin Currie Investment Management Limited Company Secretary
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