Treasury Shares - ACT Response

Dear Peter

DTI consultative document entitled Treasury Shares dated September, 2001

Please find attached the response of The Association of Corporate Treasurers (ACT) to the questions listed in Annex of the above consultative document. Our response does not include a review of Annexes C and D.

We hope that you find our comments useful and thank you for having given us the opportunity to comment on this subject. If you wish to discuss further any of the issues raised in our response please contact our technical team on 0207 213 0738 or by email.

Yours sincerely

Jon Boyle
Chairman of Technical Committee