BRITISH EMPIRE SECURITIES AND GENERAL TRUST PLC  (the 'Company')    

 Listing Rule 15.5.1 (4) - Transactions in a Close Period  

In accordance with Listing Rule 15.5.1 (4), the Directors of the Company confirm that they are satisfied that all inside information known to the Directors and the Company up to the date of this notice has been notified to a Regulated Information Service ('RIS'). The Company is therefore exempt during the Close Period from the provisions of the Model Code in respect of dealings by persons discharging managerial responsibilities and purchases of its own securities. If prior to the announcement of the annual results for the year ended 30 September 2009 the Directors or the Company come into possession of any unpublished inside information, this will be notified to a RIS before any such transactions are undertaken.

Phoenix Administration Services Limited - Secretary

8 October 2009