RNS Number:2753K
Arbuthnot
23 April 2003

                                                             FORM 38.5 (SUMMARY)

Lodge with Company Announcements Office and the Panel. Use a separate form for
each class of securities in which dealings have been made.


CONNECTED EXEMPT MARKET-MAKERS:
DISCLOSURE UNDER RULE 38.5 OF THE CITY CODE ON TAKEOVERS AND MERGERS


Name of EMM. ARBUTHNOT

Date of disclosure. 23 April 2003

Contact name. Richard Kemp

Telephone number 0207 002 4643

Please see attached disclosure of dealings under Rule 38.5 in the securities
of the following companies:

Bullough

AMENDMENT

If the attached Rule 38.5 disclosure is to amend a previous disclosure, please
state which element(s) of previous disclosure was incorrect:

........................................................................

........................................................................

........................................................................

In the case of option business or dealings in derivatives full details should
be given on a separate sheet so that the nature of the dealings can be fully
understood. For options this include the number of securities under option,
the exercise period (or in the case of exercise, the exercise date),
the exercise price and any option money paid or received. For derivative
this should include, at least, the number of reference securities to which
they relate (when relevant), the maturity date (or if applicable the closing
out date) and the reference price.

For full details of the disclosure requirements see Rules 8 and 38 of the Code.
If in doubt contact the Monitoring Section of the Panel, Tel. No: 020 7638 0129


FORM 38.5

CONNECTED EXEMPT MARKET-MAKERS:
DISCLOSURE UNDER RULE 38.5 OF THE CITY CODE ON TAKEOVERS AND MERGERS


Dealing in. Bullough


Class of security. Ordinary

Date of dealing 22 April 2003



Name of EMM. ARBUTHNOT


Name of offeree/offeror with whom connected Bullough


Total number of securities purchased


Highest price paid* GBP


Lowest price paid* GBP




Total number of securities sold. 25,000



Highest price received* GBP 11.50p



Lowest price received* GBP  11.5p



*Currency must be stated




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