Portfolio disclosure

British Empire Sec & Gen Tst PLC
02 February 2004

BRITISH EMPIRE SECURITIES AND GENERAL TRUST p.l.c.

In accordance with Listing Rule 21.20 (l)(i), British Empire Securities and
General Trust p.l.c. announces that as at 31 January 2004 it had the following
holdings in other UK listed investment companies (including listed investment
trusts) which do not have a stated investment 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                                       23,888,393                            5.79
Advance UK Trust                                                6,929,600                            1.68
Rutland Trust                                                   2,443,513                            0.59
Hansa Trust                                                     2,190,500                            0.53
Total                                                                                                8.59







For Phoenix Administration Services Limited

Secretary

3 February 2004


                      This information is provided by RNS
            The company news service from the London Stock Exchange