Listing Rule 21.20

British Empire Sec & Gen Tst PLC
04 April 2005


BRITISH EMPIRE SECURITIES AND GENERAL TRUST PLC

In accordance with Listing Rule 21.20 (l)(i), British Empire Securities and
General Trust plc announces that as at 31 March 2005 it had the following
holdings in other UK listed investment companies (including listed investment
trusts) which do not have a stated investment policy to invest no more than 15%
of their gross assets in other listed UK investment companies (including listed
investment trusts):
                                                         Market Value (£)         Percentage of portfolio
Name
Hansa Trust 'A' Ordinary                                       13,714,303                            2.59
Advance UK Trust                                                8,633,600                            1.63
Utilico Investment Trust plc Ordinary                           2,789,069                            0.53
Hansa Trust Ordinary                                            1,860,991                            0.35
Total                                                          26,997,963                            5.10


In accordance with Listing Rule 21.20 (l)(ii), British Empire Securities and
General Trust plc announces that at 31 March 2005 the ten largest investments
were as follows:
                                                         Market value (£)         Percentage of portfolio
Company
Treasury 8.5% 07/12/2005                                       41,044,000                            7.75
Treasury 7.75% 08/09/2006                                      36,498,000                            6.90
Eurazeo NPV                                                    23,330,713                            4.41
Jardine Strategic Holdings                                     22,066,697                            4.17
Law Debenture Corp plc                                         18,463,594                            3.49
Prospect Japan Fund Ltd                                        16,061,211                            3.03
CNP-CIE Natle a Portefeuille NPV                               15,822,368                            2.99
Hansa Trust plc 'A' Ord                                        13,714,303                            2.59
Wendel Investissement EUR4                                     12,322,574                            2.33
European Asset Value Fund NPV                                  11,605,105                            2.19
Total                                                         210,928,565                           39.85


Except as stated above there were no investments with a value greater than 5% of
the Company's portfolio.

Phoenix Administration Services Limited - Secretary
4 April 2005


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