Listing Rule 21

Lowland Investment Co PLC
05 January 2004

LOWLAND INVESTMENT COMPANY PLC

HENDERSON GLOBAL INVESTORS

5 JANUARY 2004







                         LOWLAND INVESTMENT COMPANY PLC


                                Listing Rule 21



In accordance with paragraph 21.20 (l) (ii) of the Listing Rules, Lowland
Investment Company plc announces its top ten holdings, including all holdings
with a value greater than 5% of its gross assets, as at 31 December 2003:


Company            % Total Assets

McAlpine                   3.11

BP                         2.69

GlaxoSmithKline            2.68

Renold                     2.62

Avon Rubber                1.99

Lloyds TSB Group           1.96

Johnson Service Group      1.89

Shell Transport & Trading  1.89

EMI Group                  1.66

Homestyle Group            1.61







                                    - ENDS -



For further information, please call:


James Henderson

Lowland Investment Company plc

Telephone: [phone]


Stephen Westwood

Head of Investment Trusts

Henderson Global Investors

Telephone: [phone]


Stephen Phillips

Associate Director

Henderson Global Investors

Telephone: [phone]



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