Largest Holdings

SMALL COMPANIES DIVIDEND TRUST PLC

In accordance with UKLA Listing Rule 21.20(l)(ii), the following list
represents the Company's 10 largest investments as at 31 January 2004 and where
appropriate, any investment with a value greater than 5% of the Company's gross
assets:

Name of company Class of share

DEE VALLEY                                            ORDINARY             
                                                                           
SAVILLS                                               ORDINARY             
                                                                           
HITACHI CAPITAL (UK)                                  ORDINARY             
                                                                           
BROADCASTLE                                           ORDINARY             
                                                                           
NORTHUMBRIAN WATER                                    ORDINARY             
                                                                           
CLARKSON                                              ORDINARY             
                                                                           
BRAEMAR SEASCOPE SHIPPING                             ORDINARY             
                                                                           
HILL & SMITH HOLDINGS                                 ORDINARY             
                                                                           
PENDRAGON                                             ORDINARY             
                                                                           
LOOKERS                                               ORDINARY             

3 February 2004