Performance at month end

IMPAX ENVIRONMENTAL MARKETS plc

All information is at 31 October 2005 and unaudited

DATA AND PERFORMANCE


Data                            Pricing & Performance
                                                  IEM    MSCI  Impax
                                                  Net   World   ET50
Share Price                                      Asset
(pence)                    87.5                  Value
Total Fund Size        GBP 43.6 Pence (31.10.05)  87.2   n/a    n/a
(m)
Market                 GBP 43.8 Premium/discount +0.4%
Capitalisation (m)
Management fee             1.0%
Established         22 February      Performance
                           2002
Fund structure       Investment      1 month (%) -7.7%  -2.5%  -7.6%
                          Trust
Number of stocks             65     3 Months (%) -1.0%  -0.1%  -2.4%
held
Exchange                 London       1 year (%) +22.7% +15.2% +24.6%
Currency                    GBP       3 year (%) +58.5% +33.2% +37.5%
ISIN Number        GB0031232498 Year to date (%) +13.9% +10.7% +16.0%
Sedol                   3123249
Reuters RIC Code          IEM.L
Bloomberg Code           IEM LN


TOP TEN HOLDINGS


Company             Holding %   Description                Country
Vestas Wind Systems       3.5   Wind                       Denmark
Casella Waste             3.2   Waste disposal & recycling US
Kurita Water              2.9   Water treatment            Japan
Itron                     2.8   Meters & software          US
RPS Group                 2.8   Environmental consulting   UK
LKQ                       2.5   Automotive recycling       US
Stericycle                2.4   Clinical waste             US
Pall Corp                 2.3   Filtration                 US
BWT                       2.2   Water treatment            Austria
Zenon Environmental       2.1   Membranes                  Canada

Total                    26.7


PORTFOLIO ANALYSIS*


Geographical           Company Size
North America      49% >£500m         37%
Europe             43% £100-500m      44%
Rest of the World  8%  <£100m         19%

Sectoral               Profitability
Energy             41% Profitable     88%
Water              28% Pre-Profitable 12%
Waste              31%
Cash               0%
* of funds invested as of 31 October 2005














MANAGER'S COMMENTARY (October 2005)


The Company NAV was down 7.7% over the month compared to the MSCI
World which fell 2.5%, and the Impax ET50, which fell 7.6% over the
same period.  Within the broader equity markets, energy was the worst
performing sector, followed by the other resource sectors.

During the month the United Nations Clean Development Mechanism
Executive Board approved the first Certified Emissions Reductions
("CERs") to two hydroelectric projects in Honduras.  Industrialised
countries can purchase CERs in order to offset their own internal CO2
reduction targets under the Kyoto Protocol.  In the US, the Bush
administration announced plans to explore renewables, hydrogen and
clean coal, alongside nuclear technologies, under the terms of its
draft strategic plan for the $3 billion US Climate Change Technology
Program.  In Germany, according to a draft deal between the CDU and
SPD parties, the next coalition government will maintain its
commitment of ensuring that renewable sources make up at least 20
percent of the country's overall energy requirement by 2020.  The
announcement was made in the wake of Q-Cell's successful IPO on the
Frankfurt Borse, which valued the solar cell manufacturer at ¤1.8
billion.  The company raised ¤242 million, with which it intends to
move out of the German market and away from dependence on government
subsidies.  The other notable IPO was that of Indian wind turbine
manufacturer Suzlon Energy, which successfully completed its listing
on the Bombay Stock Exchange, with the issue more than 45 times
oversubscribed.  Outside of the energy sector, the Chinese government
announced plans to use desalinated seawater to supply 16 to 24
percent of water used in coastal areas by 2010.  Hundreds of cities
in China are suffering from water shortages due to population
pressure and the countries' surging economic growth.

Companies that contributed to the month's underperformance included
Calgon Carbon (air & water treatment, US, -31%) after a profit
warning on delays and rising costs, and the non-profitable
alternative energy companies such as Active Power (flywheels, US,
-21%), American Superconductors (superconductors, US, -21%),
Hydrogenics (fuel cells, Canada, -21%) and Fuelcell Energy (fuel
cells, US, -20%).  On the upside, Bioteq (effluent treatment, Canada,
+7%) continued to win contracts using the EPA's "preferred
technology", whilst PM Group (weighing devices, UK, +5%) resisted the
weakness in small cap stocks.

During the month we participated in the Q-Cells IPO.


Latest information available at: www.impax.co.uk/asset/iemdown.htm

23 November 2005




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