Portfolio Update

British Empire Sec & Gen Tst PLC
05 January 2005


BRITISH EMPIRE SECURITIES AND GENERAL TRUST PLC

In accordance with Listing Rule 21.20 (l)(i), British Empire Securities and
General Trust plc announces that as at 31 December 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                                       31,071,448                            6.20

Advance UK Trust                                                8,108,200                            1.62

Hansa Trust Ordinary                                            2,225,874                            0.44

Utilico Investment Trust plc Ordinary                           1,850,679                            0.37

Total                                                                                                8.63


In accordance with Listing Rule 21.20 (l)(ii), British Empire Securities and
General Trust plc announces that at 31 December 2004 the ten largest investments
were as follows:

Company                                                  Market value (£)         Percentage of portfolio

Treasury 8.5% 07/12/2005                                       46,674,000                            9.31

Hansa Trust plc 'A' Ord                                        31,071,448                            6.20

Eurazeo NPV                                                    26,612,080                            5.31

Jardine Strategic Holdings                                     24,219,974                            4.83

Treasury 7.75% 08/09/2006                                      21,078,000                            4.20

Law Debenture Corp plc                                         17,292,188                            3.45

Wendel Investissement EUR4                                     16,886,559                            3.37

Prospect Japan Fund Ltd                                        15,964,506                            3.18

CNP-CIE Natle a Portefeuille                                   15,317,378                            3.05

European Asset Value Fund NPV                                  10,892,863                            2.17

Total                                                                                               45.07

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

Phoenix Administration Services Limited - Secretary
5 January 2005


                      This information is provided by RNS
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