Portfolio disclosure

British Empire Sec & Gen Tst PLC
05 January 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 December 2003 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                                       22,235,963                            5.33
Advance UK Trust                                                6,787,600                            1.63
Rutland Trust                                                   2,392,250                            0.57
Hansa Trust                                                     2,042,271                            0.49
Total                                                                                                8.02

In accordance with Listing Rule 21.20 (l)(ii), British Empire Securities and
General Trust p.l.c. announces that at 31 December 2003 the ten largest
investments were as follows:
Company                                                  Market value (£)         Percentage of portfolio
Treasury 5% 07/06/2004                                         39,202,799                            9.40
Rue Imperiale                                                  28,924,063                            6.94
Hansa Trust 'A' Ordinary                                       22,235,963                            5.33
Wendel Investissement                                          16,662,909                            4.00
Law Debenture Corp                                             15,716,531                            3.77
Henderson Electrical & General Investment
Trust                                                          14,454,050                            3.47
Prospect Japan Fund                                            13,824,757                            3.32
Investor AB 'A' SEK6.25                                        13,275,357                            3.18
Jardine Strategic Holdings                                     12,187,279                            2.92
EnCana Corp                                                    10,889,171                            2.61
Total                                                                                               44.94

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



For Phoenix Administration Services Limited

Secretary

5 January 2004


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