ASEI.L Regulatory News (ASEI)

ABERDEEN STANDARD EQUITY INCOME TRUST PLC

HALF-YEARLY FINANCIAL REPORT

FOR THE SIX MONTHS ENDED 31 MARCH 2019

Objective

To provide Shareholders with an above average income from their equity investment, while also providing real growth in capital and income.

Investment policy

The management of the Company's investments and the day to day operation of the Company is delegated to Aberdeen Standard Fund Managers Limited ("the Manager").

The Directors set the investment policy which is to invest in a diversified portfolio consisting mainly of quoted UK equities which will normally comprise between 50 and 70 individual equity holdings.

In order to reduce risk in the Company without compromising flexibility:

• no holding within the portfolio will exceed 10% of net assets; and

• the top ten holdings within the portfolio will not exceed 50% of net assets.

The Company may invest in convertible preference shares, convertible loan stocks, gilts and corporate bonds.

The Directors set the gearing policy within which the portfolio is managed. The parameters are that the portfolio should operate between holding 5% net cash and 15% net gearing. The Directors have delegated responsibility to the Manager for the operation of the gearing level within the above parameters.

For further information, please contact:

James Thorneley

Press Office

Aberdeen Standard Investments Tel: 020 7463 6323

Evan Bruce-Gardyne

Client Director, Investment Trusts

Aberdeen Standard Investments Tel: 0131 245 0571

Strategic Report

Key Financial Highlights

Total return* for periods to 31 March 2019

As at 31 March 2019

For the six months to 31 March 2019

* Considered to be an Alternative Performance Measure.

Chairman's Statement

Performance

The performance of the portfolio over the six months under review was poor, with the net asset value total return being -7.0%, compared with the benchmark total return of -1.8%. The share price also suffered and the share price total return for the period was -9.1%. This was reflected in a widening of the discount from 2.5% in September 2018 to 4.7% at the end of March. It was very much a period of two halves, with the final quarter of 2018 being the worst fourth calendar quarter for the British market since 1987, and mid and small cap companies, in which we are heavily invested, underperforming large cap stocks. This pattern was reversed in the first quarter of this year, but our relative improvement was not sufficient to make up much of the ground lost in the last three months of 2018.

Revenue

Total income for the period of £5.212m was very similar to last year's £5.251m. Management fees and administrative expenses charged to the revenue account were also in line, £438k in 2019 compared to £451k in 2018. After interest costs and tax, net earnings were down 2.0% at £4.638m and the revenue per Ordinary Share was 9.43p compared to 9.62p in 2018. While this is marginally below the cumulative level of the dividends distributed, the revenue forecasts indicate that, as is typical, more income will be generated in the second half of the financial year than in the first half.

Dividends

The Board is declaring a second quarterly dividend of 4.9p per share, bringing total dividends for the six months to 31 March 2019 to 9.8p per share, an increase of 11.4% on the 8.8p paid for the six months to 31 March 2018. This second quarterly dividend will be paid on 21 June 2019 to Shareholders on the register on 31 May 2019, with an associated ex-dividend date of 30 May 2019. The Board's intention is that the third quarterly dividend, which will be paid in September, will be 4.9p per share and that the final dividend, in January 2020, will be not less than 5.5p per share. Cumulatively, this would amount to a dividend for the year of 20.2p per share, which the Board expects to be covered by earnings in the current year. This will represent an increase of 5.2% on last year's 19.2p per share.

Gearing

As foreshadowed in the Annual Report, the Company now has a £40m revolving credit facility with Banco Santander S.A., London Branch, replacing the £30m funding which had previously been provided by Scotiabank (Ireland) Limited up to 17 December 2018. This new facility was in use from that date and £30m was drawn at the end of the period at a weighted average cost of 1.9%. At the end of the period, net gearing amounted to 12.0% of net assets.

Being geared in investments that generally fell in value exacerbated the negative performance of the portfolio by 0.8%.

Governance and Board

As part of the Board's succession planning, Jo Dixon has indicated that she will stand down from the Board following the Annual General Meeting to be held in 2020. Jo has been a valuable member of the Board since 2011, and Chairman of the Audit Committee since 2012, and her knowledge and contribution will be missed. A process to identify a successor has begun and a further announcement on this will be made in due course.

Aberdeen Standard Investments Savings Plans

The Board has agreed to participate in the Aberdeen Standard Investments promotional programme which it hopes will help to promote the appeal of the Company and to make it accessible to as wide an audience of investors as possible. Details of the savings plans available to investors can be found in the Half-Yearly Report.

Outlook

At the beginning of 2019 the general expectation was that the trend of rising interest rates, particularly in the US, would continue. This has not materialised: in the United States some fairly blunt pressure from the White House seems to have deterred the Federal Reserve from taking any further action to tighten policy; the yield curve has flirted with inverting (the position where short-dated interest rates are higher than longer-dated ones), which implies that the bond market is pricing in a recession. In Europe, negative interest rates on German government debt have reappeared. Meanwhile in Britain the Brexit imbroglio continues without any indication of an imminent resolution. The "Euro can" has been kicked further down the road to Halloween but what the outcome will be is still as uncertain as it has been at any time in the nearly three years since the June 2016 referendum. This political situation continues to be a substantial headwind for the UK market. By contrast, the British economy continues to perform reasonably, certainly no worse than our European neighbours, with unemployment at its lowest level since 1975 and the businesses of most of our portfolio companies are performing well.

The outlook, therefore, is no less uncertain than it was when my annual statement was written on 20 November last year. The Board, while acknowledging that this has been a very disappointing six months, believes that the investment process and resources available to the Manager should produce long-term investment success.

Richard Burns

Chairman

21 May 2019

Principal Risks and Uncertainties

The Board has an ongoing process for identifying, evaluating and managing the principal risks and uncertainties of the Company and has carried out a robust review. The process is regularly reviewed by the Board. Most of the Company's principal uncertainties and risks are market related and are no different from those of other investment trusts that invest primarily in the UK listed market. Risks may vary in significance from time to time and the controls and actions to mitigate these are described below.

The Board considers the following to be the principal risks and uncertainties:

· Investment Performance The Board recognises that market risk is significant in achieving performance and consequently it reviews strategy and investment guidelines to ensure that these are appropriate. Regular reports are received from the Manager on stock selection, asset allocation, gearing and the costs of running the Company. The performance is reviewed in detail and discussed with the Portfolio Manager at each Board meeting.

The Board regularly reviews the impact of geopolitical instability and change on market risk. The Board is mindful of the continuing uncertainty following the UK's referendum decision to leave the EU and, along with the Manager, is closely monitoring the situation. 

The Board, through its review process, did not identify any specific new actions required to mitigate performance risks during the first half of the year. The Investment Manager's Report explains the changes made within the portfolio during the six months ended 31 March 2019.

· Operational Risk In common with most investment trusts, the Board delegates the operation of the business to third parties, the principal delegate being the Manager. Failure of controls and poor performance of any service provider could lead to disruption, reputational damage or loss to the Company. As part of the annual assessment of key third party service providers, the internal control reports of the service providers are reviewed.

During the period there were no issues identified that compromised the security of the assets and the Board received assurances on the internal control environment of service providers from these reports.

· Governance Risk The Directors recognise the impact that an ineffective board, unable to discuss, review and make decisions, could have on the Company and its Shareholders. The Board is aware of the importance of effective leadership and board composition and this is ensured through a regular performance evaluation of both the Chairman and the Board.

· Discount/Premium to NAV A significant share price discount or premium to net asset value per share could lead to high levels of uncertainty for Shareholders. In particular, a wide discount could potentially reduce Shareholder confidence.

The Board keeps the level of the Company's discount/premium under regular review.

· Regulatory Risk The Company operates in a complex regulatory environment and faces a number of regulatory risks. Breaches of regulations, including but not limited to, the Companies Act 2006, the Corporation Tax Act 2010, the FCA Listing Rules, the FCA Disclosure Guidance and Transparency Rules, the Market Abuse Regulation, the Foreign Account Tax Compliance Act, the Common Reporting Standard, the Packaged Retail and Insurance based Investment Product (PRIIPs) Regulation, the Markets in Financial Instruments Directive II (MiFID II) and the General Data Protection Regulation (GDPR), could lead to a number of detrimental outcomes and reputational damage.

There is also a regulatory risk in ensuring compliance with the Alternative Investment Fund Managers Directive (AIFMD). In accordance with the requirements of the AIFMD, the Company appointed Aberdeen Standard Fund Managers Limited as its AIFM with effect from 10 December 2018 (previously Standard Life Investments (Corporate Funds) Limited) and BNP Paribas Securities Services as its Depositary. The Board receives regular reporting from the AIFM and the Depositary to ensure both are meeting their regulatory responsibilities in relation to the Company.

Strategic Report

Our Strategy

Aberdeen Standard Equity Income Trust plc offers an actively managed portfolio of UK quoted companies. The investment approach is index-agnostic and the focus is on those companies delivering sustainable dividend growth.

Management

In December 2018, the investment management agreement with the Company's Manager was novated from Standard Life Investments (Corporate Funds) Limited to Aberdeen Standard Fund Managers Limited ("ASFML", the "AIFM" or the "Manager"). ASFML is a wholly-owned subsidiary of Standard Life Aberdeen plc ("SLA"). The investment management to the Company has been and continues to be provided by Aberdeen Standard Investments ("ASI"), the investment division of SLA. Thomas Moore has been the Portfolio Manager since 2011.

Investment process

The portfolio is invested on an index-agnostic basis. The process is based on a bottom-up stock-picking approach where sector allocations are a function of the sum of the stock selection decisions, constrained only by the appropriate risk control parameters. The aim is to evaluate changing corporate situations and identify insights that are not fully recognised by the market.

Idea generation and research

The vast majority of the investment insights are generated from information and analysis from one-on-one company meetings. Collectively, more than 3,000 company meetings are conducted annually across ASI. These meetings are used to ascertain the company's own views and expectations of the future prospects for their company and the markets in which they operate. Through actively questioning the senior management and key decision makers of companies, the portfolio managers and analysts look to uncover the key changes affecting the business and the materiality of their impact on company fundamentals within the targeted investment time horizon.

Investment process in practice

The index-agnostic approach ensures that the weightings of the holdings reflect the conviction levels of the investment team, based on an assessment of the management team, the strategy, the prospects and the valuation metrics. The process recognises that some of the best investment opportunities come from under-researched parts of the market where the breadth and depth of the analyst coverage that the Portfolio Manager can access provides the scope to identify a range of investment opportunities.

The consequence of this is that the Company's portfolio looks very different from many other investment vehicles providing their investors with access to UK equity income. This is because the process focuses on conviction levels rather than index weightings. This means that the Company may provide a complementary portfolio to the existing portfolios of investors who like to make their own decisions and manage their ISAs, SIPPs and personal dealing accounts themselves. Around 60% of the Company's portfolio is invested in companies outside the FTSE 100.

The index-agnostic approach further differentiates the portfolio because it allows the Portfolio Manager to take a view at a thematic level, concentrate the portfolio's holdings in certain areas and avoid others completely. The effect of this approach is that the weightings of the portfolio can be expected to differ significantly from that of any index, and the returns generated by the portfolio may reflect this divergence, particularly in the short term.

Investment Manager's Report

For the 6 months ended 31 March 2019, the NAV total return was -7.0% against the FTSE All-Share Index total return of -1.8%. The period under review was characterised by two distinct phases. The three months to December 2018 witnessed one of the most dramatic sell-offs in the UK equity market in recent years during which the portfolio experienced meaningful underperformance relative to the benchmark. Market sentiment improved in the three months to the end of March 2019 and the portfolio recovered some of its earlier underperformance.

As we have previously observed, the index-agnostic approach we adopt in managing the portfolio makes this a highly active portfolio with only limited exposure to defensive large cap stocks. While we believe that this is the right approach in the long term, it can lead to periods in which the portfolio performs significantly worse than the wider market and this was one such period.

UK market review

In the first three months of the period under review, equity markets sold off as investors worried about fading global growth, continuing US/China trade tensions, the path of monetary policy and ongoing Brexit uncertainty. This period saw a rotation from cyclical stocks into defensive stocks, with large caps significantly outperforming small and mid-caps. The sell-off reached its climax shortly before the New Year and January saw the beginning of a phase in which investors regained their composure. The key trigger causing sentiment to improve was an abrupt change in signalling by the Federal Reserve on the future path of US interest rates. Jerome Powell, the Federal Reserve Chair, said that the case for continuing to raise rates had "weakened somewhat". Market participants had previously pencilled in two rate rises in 2019, but these were immediately priced out and some forecasters predicted a rate-cut within a year. The shift in policy boosted risk appetite and stock markets rallied sharply.

Brexit remained centre stage throughout. As the period progressed, the threat of 'no-deal' Brexit increased. This culminated in Prime Minster Theresa May failing to secure enough votes for her Withdrawal Agreement for a third time. As a result, she was forced to ask the EU to delay the departure date until 12 April and the deadline was subsequently extended to 31 October 2019. While political uncertainty has not gone away, there were signs by the end of the period that investors had become hardened to it. Consumers also appeared to be taking Brexit uncertainty in their stride, helped by buoyant employment conditions, rising wage growth and improving household consumer cash flows. The UK continued to confound expectations on GDP growth, growing at a similar rate to Germany and France, although sceptics pointed to the impact of manufacturers stockpiling goods ahead of Brexit.

Portfolio performance

The portfolio's poor performance during the period can be attributed to two factors: (1) adverse market conditions during the first half of the period and (2) some sector and stock positions performing poorly. 

The three months to December 2018 saw the biggest sell-off in the UK stock market since the third quarter of 2011, when the Eurozone crisis was in full swing. Companies that bucked the trend were few and far between, with only a handful of defensive growth stocks holding up while large parts of the stock market plummeted. Given our index-agnostic investment approach, these market conditions were particularly difficult for our portfolio. Conditions improved somewhat in the first quarter of 2019, although continued nervousness was reflected in the persistent outperformance of a small number of defensive growth stocks. Such stocks do not feature heavily in our portfolio as our Focus on Change investment process points us towards stocks on low valuations with the potential for improvement in their fundamentals, rather than stocks on high valuations that are already the "finished article" and consequently market expectations are high. While we are disappointed about the returns we have generated in the period, we remain confident that our investment process, which focuses on changing investment fundamentals, will ultimately reap rewards for our Shareholders.

The second source of underperformance came from some of the sector and stock positions in the portfolio. This was concentrated in 5 sectors, shown in the table below, whose aggregate negative contribution to performance exceeded the net return of the portfolio as a whole.

Given the concentrated nature of the portfolio, there are normally only two or three positions in each sector, so the performance of each individual holding will often have a marked impact on the sector return. With the benefit of hindsight the sector positioning of the portfolio was sub-optimal going into the market sell-off, in particular its heavy weightings to cyclical and financial stocks, and its limited exposure to defensive sectors.

Within Construction & Materials the key detractors to performance were Tyman and Kier Group. Tyman was sold off aggressively on fears over the impact of rising rates on the US housing market. Kier Group's share price declined following the announcement of a rights issue designed to strengthen its balance sheet following a change in risk appetite by the banks towards the construction sector after the collapse of Carillion. GVC is the portfolio's largest position in Travel & Leisure and it fell sharply on concerns over growing regulatory challenges in some of its major markets. Within Support Services the key detractors were Staffline and Equiniti both of which suffered from severe valuation de-rating. Wood Group is the only position in the Oil Equipment, Services & Distribution sector and it was adversely affected by fears over the impact of slowing global growth on their order book. Within Banks, CYBG/Virgin Money declined on fears over the earnings impact of intensifying mortgage market competition.

The portfolio had some significant successes, notably within Financial Services where John Laing Group whose consistently strong returns drove a valuation re-rating, Litigation Capital Management which soared after its IPO on completion of litigation projects and Ashmore which delivered strong performance while improving sentiment towards Emerging Markets drove a surge in demand for its funds. While General Retailers as a sector has been enduring tough trading conditions, our holding in Dunelm bucked the trend and its January trading update led to analysts upgrading their earnings forecasts. Within Software & Computer Services, Micro Focus performed well as strong execution has helped to restore investors' faith in management's ability to hit guidance. Within Mining, both Rio Tinto and Anglo American delivered returns of over 20% in the period on rising commodity prices and disruption to global iron ore supply caused by a burst dam owned by a Brazilian competitor.

Revenue Account

The dividend income, including stock dividends, received by the portfolio during the period was £5.2m, which was 1.0% or £54k less than last year. UK investment income, which makes up 82% of the income, was down 4.7%, while the income from overseas and property income distributions was up 1.8%. 97% of the dividend income came from recurring rather than special dividends, which provides reassurance that the income is sustainable in the future.

In the three years prior to the current year, the income generated in the first six months has been between 40% and 45% of the total income for the year. Our forecasts for the full year indicate that the current year will follow this pattern and that the second half of the year will ensure that we are able to pay the projected full year dividend out of the earnings for the year.

Activity

Purchases

We bought back into Imperial Brands where we believe the market is too fearful about the impact of new competition on earnings and dividends. Imperial appears to be gaining momentum in vaping, with potential for its Blu brand to become a leading player in a consolidating market. Recent management guidance has driven earnings upgrades, which should in due course drive the share price from the starting point of a very low valuation. We also bought shares in mining business Glencore where the management team appears to be highly incentivised to deliver for shareholders. We like the diversified nature of Glencore's portfolio, with stable marketing revenues in addition to high quality mining assets. While there remain some regulatory risks, these appear to be more than fully priced in at the current valuation.

Sales

We took profits in Legal & General where management's strategy has been successful in addressing growth opportunities by linking the company's investing, annuities, investment management and insurance businesses. However, this is now better understood by the wider market, as reflected in the valuation which has moved ahead of its peers after a period of very strong share price performance. We also took profits in Dunelm where the investment case appeared to have played out and the valuation had moved ahead of its closest competitors. Dunelm's success can be attributed to management's focus on its core business which is enabling the company to overcome the headwinds being faced elsewhere in the sector. This is an example of a UK domestic stock whose share price had been under pressure from macro concerns, but which has ultimately responded to positive corporate fundamentals. We anticipate that other UK domestic stocks will follow Dunelm's lead and we expect this to be a helpful driver of the portfolio's performance in the months ahead.

Outlook

While the weak performance of the portfolio during the period was disappointing, we remain convinced in the long-term merits of our investment process which looks to identify stocks whose potential for improvement in fundamentals has not been priced into their valuations. This process tends to perform best when investors are receptive to changes in company fundamentals. This was not such a period. The primary focus for many investors during the period was fear of macro turmoil, notably slowing global growth and the risk of a hard Brexit. The result was a widening in the valuation divergence between defensive growth stocks, to which the portfolio has limited exposure, and value/income stocks, to which the portfolio has considerable exposure. We see an abundance of stocks with attractive prospects on significantly lower valuations, with scope to rebound strongly.

We remain convinced of the importance of scrutinising a stock's valuation when assessing its investment case. Many investors talk about "reassuringly high" valuations, but we beg to differ. We would rather identify companies whose valuations offer scope to increase over time as their robust fundamentals become better appreciated by the market. Our focus remains on ensuring that the portfolio is set up to generate improved returns by sticking to our investment process and identifying companies with a combination of robust fundamentals and low valuations.

Currently we are finding the most compelling investment ideas within three areas.

· Global Yield stocks - attractively valued overseas earners whose strong cash flows underpin confidence in dividend delivery (this includes resource stocks and industrials).

· Domestic Opportunities - UK- focused companies that offer the prospect of meaningful valuation re-rating as political uncertainty fades (this includes consumer and financial stocks).

· Uncorrelated Value - stocks whose growth prospects are independent of macro drivers (this includes stocks such as John Laing).

These attractive valuation opportunities exist partly as a result of the uncertain economic and political outlook.

When the current uncertainty has disappeared, valuations are likely to be meaningfully higher. While taking a non- consensual view can be uncomfortable when investing, we believe that it holds the key to achieving strong investment returns over the long term.

While the capital performance of the portfolio has been disappointing, the income that the portfolio has generated has been stable in the first half of the financial year, on the back of a 19% increase this time last year. We firmly believe that the acceleration in the portfolio's dividend growth in recent years has been supported by the index- agnostic approach, which provides the flexibility to invest in small and mid-cap stocks whose long-term dividend growth prospects appear significantly more attractive than their large cap peers. Over time we would expect this approach to support capital growth, as well as dividend growth.

Thomas Moore

Portfolio Manager

21 May 2019

Condensed Statement of Comprehensive Income

The total column of this statement represents the profit and loss account of the Company.

A Statement of Total Recognised Gains and Losses has not been prepared as all gains and losses are recognised in the Condensed Statement of Comprehensive Income.

All revenue and capital items in the above statement derive from continuing operations.

The accompanying notes are an integral part of the Financial Statements.

Condensed Statement of Financial Position

The Financial Statements of Aberdeen Standard Equity Income Trust plc, registered number 2648152, were approved by the Board of Directors and authorised for issue on 21 May 2019 and were signed on its behalf by:

Richard Burns

Chairman

Condensed Statement of Changes in Equity

Six months ended 31 March 2019 (unaudited)

Condensed Statement of Changes in Equity

Six months ended 31 March 2018 (unaudited)

Notes to the financial Statements

1. Accounting policies

Basis accounting

The condensed Financial Statements have been prepared in accordance with Financial Reporting Standard 104 (Interim Financial Reporting) and with the Statement of Recommended Practice for 'Financial Statements of Investment Trust Companies and Venture Capital Trusts' issued in November 2014 and updated in February 2018 with consequential amendments. They have also been prepared on a going concern basis and on the assumption that approval as an investment trust will continue to be granted.

The Half-Year Financial Statements and the net asset value per share figures have been prepared in accordance with FRS 102 using the same accounting policies as the preceding annual accounts.

2. Income

3. Taxation on ordinary activities

The taxation charge for the period, and the comparative period, represents withholding tax suffered on overseas dividend income.

4. Return per ordinary share

The figures above are based on the following figures:

* Calculated excluding shares in treasury. At 31 March 2019 there were 15,985 shares in treasury (2018: 15,985).

5. Dividends

The third interim dividend for the financial year to 30 September 2017 was declared on 1 September 2017 with an ex-dividend date of 14 September 2017. This dividend of 4.00p per share was paid 6 October 2017 (during the six months ended 31 March 2018) and was not included as a liability in the Financial Statements to 30 September 2017.

6. Called-up share capital

No Ordinary shares were repurchased during the six months ended 31 March 2019 or 31 March 2018.

7. Capital reserve

The capital reserve figure reflected in the Condensed Statement of Financial Position includes investment holdings gains at the period end of £2,603,400 (30 September 2018: gains of £28,901,930) which relate to the revaluation of investments held at the reporting date and realised gains of £126,275,743 (30 September 2018: £121,773,085).

8. Net asset value per ordinary share

* Excludes shares in issue held in treasury. At 31 March 2019 there were 15,985 shares in treasury (2018: 15,985).

9. Transaction costs

During the period expenses were incurred in acquiring or disposing of investments classified as fair value through profit or loss. These have been expensed through capital and are included within losses on investments in the Condensed Statement of Comprehensive Income. The total costs were as follows:

10. Loans

The loan facility by Scotiabank (Ireland) Limited was repaid on 17 December 2018 and refinanced by a £40,000,000 facility provided by Banco Santander S.A., London Branch. The facility consists of a five year revolving facility which has a maturity date of 20 November 2023.

At 31 March 2019, £30,000,000 had been drawn down (30 September 2018: £30,000,000) at a rate of 1.846% (30 September 2018: 1.57463%).

The loan is shown in the Condensed Statement of Financial Position net of amortised expenses of £149,000.

11. Fair Value Hierarchy

FRS 102 requires an entity to classify fair value measurements using a fair value hierarchy that reflects the significance of the inputs used in making the measurements. The fair value hierarchy shall have the following classifications:

Level 1: quoted prices (unadjusted) in active markets for identical assets or liabilities;

Level 2: inputs other than quoted prices included within Level 1 that are observable for the assets or liabilities, either directly (ie as prices) or indirectly (ie derived from prices); and

Level 3: inputs for the assets or liabilities that are not based on observable market data (unobservable inputs).

All of the Company's investments are in quoted equities (30 September 2018: same) that are actively traded on recognised stock exchanges, with their fair value being determined by reference to their quoted bid prices at the reporting date. The total value of the investments have therefore been deemed as Level 1 (30 September 2018: same).

12. Half-Yearly Report

The financial information contained in this Half-Yearly Financial Report does not constitute statutory accounts as defined in Sections 434-436 of the Companies Act 2006. The financial information for the six months ended 31 March 2019 and 31 March 2018 has not been audited.

The information for the year ended 30 September 2018 has been extracted from the latest published audited Financial Statements which have been filed with the Registrar of Companies. The report of the auditors on those accounts contained no qualification or statement under Section 498 (2), (3) or (4) of the Companies Act 2006.

This Half-Yearly Financial Report was approved by the Board on 21 May 2019.

Directors' Responsibility Statement

The Directors are responsible for preparing the Half-Yearly Financial Report in accordance with applicable laws and regulations. The Directors confirm that to the best of their knowledge -

· the condensed set of Financial Statements have been prepared in accordance with the Accounting Standards Board's statement "Half-Yearly Financial Reports"; and

· the Interim Management Report includes a fair review of the general conditions required by 4.2.7R and 4.2.8R of the Financial Conduct Authority's Disclosure Guidance and Transparency Rules.

The Half-Yearly Financial Report, for the six months ended 31 March 2019, comprises an Interim Management Report, in the form of the Chairman's Statement, the Directors' Responsibility Statement and a condensed set of Financial Statements, which has not been audited or reviewed by the auditors pursuant to the Accounting Principles Board guidance on Review of Interim Financial Information.

For and on behalf of the Directors of Aberdeen Standard Equity Income Trust plc.

Richard Burns

Chairman

21 May 2019