Portfolio Disclosure

British Empire Sec & Gen Tst PLC
02 July 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 30 June 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                                       25,864,124                            5.75
Advance UK Trust                                                7,100,000                            1.58
Hansa Trust                                                     2,381,551                            0.53
Total                                                                                                7.86

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

Company                                                  Market value (£)         Percentage of portfolio
Eurazeo NPV                                                    27,748,583                            6.17
Hansa Trust 'A' Ordinary                                       25,864,124                            5.75
Henderson Electrical & General                                 19,726,022                            4.39

Investment Trust
Prospeact Japan Fund                                           17,997,000                            4.00
Jardine Strategic Holdings                                     16,103,790                            3.58
Law Debenture Corp                                             15,618,750                            3.47
Wendel Investissement                                          12,613,371                            2.80
EnCana Corp                                                    11,705,055                            2.60
CNP-CIE Natle a Portefeuille                                   10,245,026                            2.28
European Asset Value Fund                                       9,601,898                            2.13
Total                                                                                               37.17


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



For Phoenix Administration Services Limited
Secretary
1 July 2004


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