Portfolio Update

Gresham House plc

36 Elder Street, London E1 6BT

Listing Rule 21.20(l)(ii)

In  accordance with 21.20(l)(ii) of the Listing Rules we detail below a list  of
the 10 largest investments (which include all those with a value greater than 5%
of the portfolio) as at 31st December, 2008:-

                                          Market           % of
                                           Value      Portfolio
                                           £'000
UK Listed Securities
British American Tobacco                     224           3.26
Welsh Industrial Investment Trust plc        455           6.62

Securities dealt in under AIM
Hallin Marine Subsea International plc     3,108          45.20
Portland plc                                 125           1.82
SpaceandPeople plc                           714          10.39

Securities dealt in under PLUS Market
Wheelsure Holdings plc                       120           1.75

Unlisted Securities
Audiogravity Holdings Limited                228           3.31
Beyond Technologies Limited                  140           2.04
Gizmo Packaging Limited                      200           2.91
Xceed Imaging Limited                        200           2.90
                                           -----          -----
                                           5,514          80.20
                                           =====          =====

B J Hallett
Director & Company Secretary
Gresham House plc

Telephone:     [phone]

2nd January, 2009