Portfolio disclosure

British Empire Sec & Gen Tst PLC
02 April 2004

BRITISH EMPIRE SECURITIES AND GENERAL TRUST p.l.c.

In accordance with Listing Rule 21.20 (l)(i), British Empire Securities and
General Trust p.l.c. announces that as at 31 March 2004 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):

Name                                                     Market Value (£)         Percentage of portfolio
Hansa Trust 'A' Ordinary                                       24,894,220                            5.79
Advance UK Trust                                                7,156,800                            1.66
Rutland Trust                                                   2,426,425                            0.56
Hansa Trust                                                     2,305,790                            0.54
Total                                                                                                8.55

In accordance with Listing Rule 21.20 (l)(ii), British Empire Securities and
General Trust p.l.c. announces that at 31 March 2004 the ten largest investments
were as follows:

Company                                                  Market value (£)         Percentage of portfolio
Rue Imperiale                                                  27,275,734                            6.34
Hansa Trust 'A' Ordinary                                       27,200,010                            6.33
Prospect Japan Fund                                            18,402,293                            4.28
Henderson Electrical & General Investment
Trust                                                          17,945,074                            4.17
Wendel Investissement                                          17,901,516                            4.16
Law Debenture Corp                                             15,990,625                            3.72
Jardine Strategic Holdings                                     15,242,884                            3.54
EnCana Corp                                                    11,592,417                            2.70
Groupe Bruxelles Lambert                                        9,859,579                            2.29
Baillie Gifford Japan Trust                                     9,765,750                            2.27
Total                                                                                               39.80

There were no additional investments with a value greater than 5% of the
Company's portfolio.


For Phoenix Administration Services Limited
Secretary
2 April 2004


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