Investments in Investment Cos

British Empire Sec & Gen Tst PLC
02 December 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 30 November 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                                       30,748,603                           6.61%

Advance UK Trust                                                7,781,600                           1.67%

Hansa Trust Ordinary                                            2,399,432                           0.52%

Total                                                          40,929,635                           8.80%

Phoenix Administration Services Limited
Secretary
2 December 2004


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