Listing Rule 21

Brunner Investment Trust PLC
05 January 2004


In accordance with the Listing Rules Chapter 21.20 l (i), the Company announces
that at close of business on 31 December 2003 it had the following investments
in other listed investment companies (including listed investment trusts) which
themselves do not have stated investment policies to invest no more than 15% of
their gross assets in other listed investment companies (including listed
investment trusts):

None.

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