Listing Rule 21.20

British Empire Sec & Gen Tst PLC
03 May 2005



BRITISH EMPIRE SECURITIES AND GENERAL TRUST PLC

In accordance with Listing Rule 21.20 (l)(i), British Empire Securities &
General Trust plc announces that as at 30 April 2005 it had the following 
holdings in other UK listed investment companies (including listed investment 
trusts) not having a stated policy to invest no more than 15% of their gross 
assets in other listed UK investment companies (including listed investment 
trusts):

Name                                                  Market Value (£)                           Percentage of portfolio

Hansa Trust 'A' Ordinary                                    13,438,260                                             2.61%
Advance UK Trust                                             8,094,000                                             1.57%
Utilico Investment Trust plc Ordinary                        2,807,662                                             0.55%
Hansa Trust Ordinary                                         1,782,080                                             0.35%
Total                                                       26,122,002                                             5.08%

Phoenix Administration Services Limited - Secretary
3 May 2005


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