Holding(s) in Company

Graphite Enterprise Trust PLC
19 March 2002


Schedule 10 - Notification of Major Interests in Shares

1   Name of company:
GRAPHITE ENTERPRISE TRUST PLC

2   Name of shareholder having a major interest:
ROYAL & SUN ALLIANCE

3   Please state whether notification indicates that it is in respect of
holding of the shareholder named in 2 above or in respect of a non-beneficial
interest or in the case of an individual holder if it is a holding of that
person's spouse or children under the age of 18:


4   Name of registered holder(s) and, if more than one holder, the number of
shares held by each of them:
LITTLEDOWN NOMINEES LIMITED R ACCOUNT FOR PHOENIX ASSURANCE PUBLIC LIMITED
COMPANY - 940,000
LITTLEDOWN NOMINEES LIMITED R ACCOUNT FOR ROYAL & SUN ALLIANCE LIFE & PENSIONS
LIMITED - 3,913,000
LITTLEDOWN NOMINEES LIMITED R ACCOUNT FOR SUN ALLIANCE & LONDON ASSURANCE
COMPANY LIMITED - 3,200,000
ROYAL HERITAGE LIFE ASSURANCE LIMITED - 1,180


5   Number of shares/amount of stock acquired:


6   Percentage of issued class:


7   Number of shares/amount of stock disposed:


8   Percentage of issued class:


9   Class of security:
ORDINARY

10  Date of transaction:
NOT DISCLOSED

11  Date company informed:
19 MARCH 2002

12  Total holding following this notification:
8,054,180

13  Total percentage holding of issued class following this notification:
8.73%

14  Contact name for queries:
AMANDA CURTIS

15 Contact telephone number:
020 7825 5300

16  Name of company official responsible for making notification:
AMANDA CURTIS

17  Date of notification:
19 MARCH 2002

Additional Information:


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