Portfolio Disclosure

British Empire Sec & Gen Tst PLC
04 October 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 plc announces that as at 30 September 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                                       27,815,187                            6.03
Advance UK Trust                                                7,582,800                            1.64
Hansa Trust                                                     2,495,085                            0.54
Total                                                                                                8.21

In accordance with Listing Rule 21.20 (l)(ii), British Empire Securities and
General Trust plc announces that at 30 September 2004 the ten largest
investments were as follows:


Company                                                  Market value (£)         Percentage of portfolio
Hansa Trust 'A' Ordinary                                       27,815,187                            6.03
Eurazeo                                                        26,699,361                            5.78
Treasury 8.5% 07/12/2005                                       26,129,999                            5.66
Treasury 6.75% 26/11/2004                                      21,625,425                            4.69
Henderson Electric & General Investment                        21,483,787                            4.65
Trust plc
Jardine Strategic Holdings                                     20,995,714                            4.55
Law Debenture Corp plc                                         16,325,313                            3.54
Prospect Japan Fund Ltd                                        16,243,073                            3.52
Wendel Investissement EUR4                                     14,269,590                            3.09
CNP-CIE Natle a Portefeuille                                   12,755,384                            2.76
Total                                                                                               44.27

Except as stated above there were no investments with a value greater than 5% of
the Company's portfolio.

Phoenix Administration Services Limited
Secretary
4 October 2004


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