Investment in Investment Cos

British Empire Sec & Gen Tst PLC
01 November 2004

BRITISH EMPIRE SECURITIES AND GENERAL TRUST PLC

In accordance with Listing Rule 21.20 (l)(i), British Empire Securities &
General Trust plc announces that as at 31 October 2004 it
had the following holdings in other UK listed investment companies (including
listed investment trusts) not having a stated policy to invest no more than 15% 
of their gross assets in other listed UK investment companies (including listed 
investment trusts):

Name                                                     Market Value (£)         Percentage of portfolio
Hansa Trust 'A' Ordinary                                       29,729,984                           6.38%
Advance UK Trust                                                7,611,200                           1.63%
Hansa Trust Ordinary                                            2,684,795                           0.58%
Total                                                          40,025,979                           8.59%

Phoenix Administration Services Limited
Secretary
1 November 2004


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