Rule 21(l)(i) Disclosure

British Empire Sec & Gen Tst PLC
02 February 2005


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 31 January 2005 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                     31,979,361                    6.46%
Advance UK Trust                              8,321,200                    1.68%
Utilico Investment Trust plc Ordinary         2,631,021                    0.53%
Hansa Trust Ordinary                          1,786,675                    0.36%
Total                                        44,718,257                    8.97%

Phoenix Administration Services Limited
Secretary
2 February 2005


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