Rule 8.1- Aviva PLC

Aviva PLC
25 April 2005


                                                                    FORM 8.1/8.3


Lodge with a RIS or Newstrack if appropriate and the Takeover Panel.  Use a
separate form for each class of securities in which dealings have been made.


Date of Disclosure

25 April 2005


DISCLOSURE UNDER RULES 8.1(a), 8.1(b)(i) and 8.3 OF THE CITY CODE ON TAKEOVERS
AND MERGERS

Date of dealing

22 April 2005


Dealing in (name of company)

Aviva plc


1. Class of securities (eg ordinary shares)

25p ordinary shares


2.

Amount        Amount        Price
bought        sold          per unit

21            N/A           £6.045


3. Resultant total of the same class owned or controlled (and percentage of
   class)

6,095         0.0002%


4. Party making disclosure

Aviva plc

5. EITHER (a) Name of purchaser / vendor (Note 1)

Patrick Joseph Robert Snowball as beneficial owner (purchased though Hill Samuel 
(ESOP) Trustees Limited acting as trustee)

OR (b) if dealing for discretionary client(s), name of fund management
organisation

...............................................................


6. Reason for disclosure (Note 2)

...............................................................


(a) associate of

(i)  offeror (Note 3)

YES 


(ii) offeree company

NO


Specify which category or categories of associate (1-8 overleaf)

Category (3)


If category (8), explain

...............................................................

(b) Rule 8.3 (ie disclosure because of ownership or control of 1% or more of the
class of relevant securities dealt in)

NO


Signed, for and on behalf of the party named in (4) above

...............................................................


(Also print name of signatory)

Andy Hodges


Telephone and Extension number

020 7662 8444


Note 1.

Specify owner, not nominee or vehicle company. If relevant, also identify
controller of owner, eg where an owner normally acts on instructions of a
controller


Note 2.

Disclosure might be made for more than one reason; if so, state all reasons.


Note 3.

Specify which offeror if there is more than one.


Note 4.

When an arrangement exists with any offeror, with the offeree company or with an
associate of any offeror or of the offeree company in relation to relevant
securities, details of such arrangement must be disclosed, as required by Note 6
on Rule 8.


Note 5.

It may be necessary, particularly when disclosing derivative transactions, to
append a sheet to this disclosure form so that all relevant information can be
given.


Note 6.

In the case of an average price bargain, each underlying trade should be
disclosed.


Note 7.

The resultant total percentage holding of the class of relevant security is to
be calculated by reference to the percentage held and in issue outside treasury.

For full details of disclosure requirements, see Rule 8 of the Code. If in
doubt, contact the Panel on Takeovers and Mergers, Monitoring Section, Tel. No:
020 7638 0129. Email: [e-mail]


DEFINITION OF ASSOCIATE

It is not practicable to define associate in terms which would cover all the
different relationships which may exist in an offer. The term associate is
intended to cover all persons (whether or not acting in concert) who directly or
indirectly own or deal in the shares of an offeror or the offeree company in an
offer and who have (in addition to their normal interests as shareholders) an
interest or potential interest, whether commercial, financial or personal, in
the outcome of the offer.

Without prejudice to the generality of the foregoing, the term associate will
normally include the following:-
     
(1)  an offeror's or the offeree company's parent, subsidiaries and fellow
     subsidiaries, and their associated companies, and companies of which such
     companies are associated companies (for this purpose ownership or control 
     of 20% or more of the equity share capital of a company is regarded as the 
     test of associated company status);

(2)  banks and financial and other professional advisers (including 
     stockbrokers) * to an offeror, the offeree company or any company covered 
     in (1), including persons controlling#, controlled by or under the same 
     control as such banks, financial and other professional advisers;

(3)  the directors (together with their close relatives and related trusts) of 
     an offeror, the offeree company or any company covered in (1);

(4)  the pension funds of an offeror, the offeree company or any company covered
     in (1);

(5)  any investment company, unit trust or other person whose investments an
     associate manages on a discretionary basis, in respect of the relevant
     investment accounts;

(6)  a person who owns or controls 5% or more of any class of relevant 
     securities (as defined in paragraphs (a) to (d) in Note 2 on Rule 8) issued 
     by an offeror or an offeree company, including a person who as a result of 
     any transaction owns or controls 5% or more. When two or more persons act 
     pursuant to an agreement or understanding (formal or informal) to acquire 
     or control such securities, they will be deemed to be a single person for 
     the purpose of this paragraph. Such securities managed on a discretionary 
     basis by an investment management group will, unless otherwise agreed by 
     the Panel, also be deemed to be those of a single person (see Note 8 on 
     Rule 8); and

(7)  a company having a material trading arrangement with an offeror or the
     offeree company.

Paragraphs (1)-(7) are typical cases. Paragraph (8) below is a category to cover
associate status not within (1)-(7).

(8)  Other.

Notes
          
*    References to a 'bank' do not apply to a bank whose sole relationship with 
     a party to an offer is the  provision of normal commercial banking services 
     or such activities in connection with the offer as confirming that cash is
     available, handling acceptances and other registration work.

     References to 'financial and other professional advisers (including
     stockbrokers)', in relation to a party to an offer, do not include an
     organisation which has stood down, because of a conflict of interest or
     otherwise, from acting for that party in connection with the offer if the
     organisation is to have a continuing involvement with that party during the
     offer, the Panel must be consulted.  Unless the Panel is satisfied that the
     involvement is entirely unconnected with the offer, the above exclusion 
     will not normally apply.

#    The normal test for whether a person is controlled by, controls or is under
     the same control as another person will be by reference to the definition 
     of control contained in the Code.  There may be other circumstances which 
     the Panel will regard as giving rise to such a relationship (eg where a 
     majority of the equity share capital is owned by another person who does 
     not have a majority of the voting rights); in cases of doubt, the Panel 
     should be consulted.


                      This information is provided by RNS
            The company news service from the London Stock Exchange