Investment Policy

Graphite Enterprise Trust PLC
24 October 2003




                         ANNOUNCEMENT TO STOCK EXCHANGE

                         GRAPHITE ENTERPRISE TRUST PLC

                                23 October 2003


The Board of Graphite Enterprise Trust PLC (the 'Company') notes the publication
of the Investment Entities (Listing Rules and Conduct of Business) Instrument
2003 and announces that it is the Company's policy to invest no more than 15% of
its gross assets in other listed investment companies (including listed
investment trusts).



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