10th Sep 2008 11:33
| 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 PRINCIPLE TRADER: | 
| DISCLOSURE UNDER RULE 38.5 OF THE CITY CODE ON TAKEOVERS AND | 
| Name of EPT | Merrill Lynch International | 
| Date of disclosure | 10 September 2008 | 
| Date of dealing | 09 September 2008 | 
| Telephone number | 020 7996 2121 | 
| Please see attached disclosure of dealings under Rule 38.5 in the securities of the following | 
| 09 September 2008 | 
| Rio Tinto Plc - Common | 
| Imperial Energy Corporation Plc - Common | 
| BHP Billiton Limited - Common | 
| Banco Santander SA. - Common | 
| FORM | 
| 38.5(a) | 
| DEALINGS BY CONNECTED EXEMPT PRINCIPAL TRADERS | 
| (Rule 38.5 of The City Code on Takeovers and Mergers) | 
| 1. KEY INFORMATION | 
| Name of exempt principal trader | Merrill Lynch International | 
| Company dealt in | Rio Tinto Plc | 
| Class of relevant security to which the | Common | 
| dealings being disclosed relate | 
| Date of dealing | 09/09/2008 | 
| 2. DEALINGS | 
| (a) Purchases and sales | 
| Total number of securities | Highest price paid | Lowest price paid | 
| purchased | 
| 953,280 | GBP 44.54 | GBP 41.79 | 
| Total number of securities sold | Highest price received | Lowest price received | 
| 906,427 | GBP 44.54 | GBP 41.76 | 
| (b) Derivatives transactions (other than options) | 
| Product name, | Short/Long | Number of securities | Price per unit | 
| eg. CFD | 
| Long Swap | LONG | 38,325 | GBP 42.84 | 
| Long Swap | LONG | 40 | GBP 42.20 | 
| Long Swap | LONG | 295 | GBP 42.15 | 
| Long Swap | LONG | 1,252 | GBP 44.11 | 
| Long Swap | LONG | 1,550 | GBP 42.80 | 
| Long Swap | LONG | 3,250 | GBP 42.80 | 
| Long Swap | LONG | 20 | GBP 42.17 | 
| Long Swap | LONG | 24,715 | GBP 42.84 | 
| Long Swap | LONG | 20,000 | GBP 44.32 | 
| Product name, | Short/Long | Number of securities | Price per unit | 
| eg. CFD | 
| Short Swap | SHORT | 657 | GBP 41.79 | 
| Short Swap | SHORT | 24,715 | GBP 44.18 | 
| Short Swap | SHORT | 20,000 | GBP 44.49 | 
| Short Swap | SHORT | 17,344 | GBP 44.18 | 
| Short Swap | SHORT | 10,337 | GBP 44.18 | 
| Short Swap | SHORT | 6,087 | GBP 44.18 | 
| Short Swap | SHORT | 2,060 | GBP 44.11 | 
| (c) Options transactions in respect of existing securities | 
| (i) Writing, selling, purchasing or varying | 
| Product name | Writing, | Number of | Exercise | Type, e.g. | Expiry date | Option | 
| selling, | securities under | price | American, | money | 
| eg call option | purchasing, | option | European etc | paid/received | 
| varying etc. | per unit | 
| Warrant | Selling | -5,000 | £0.19 | AMERICAN | 17-Oct-08 | 
| (ii) Exercising | 
| Product name | Number of securities under | Exercise price | 
| eg call option | option | 
| 3. OTHER INFORMATION | 
| Agreements, arrangements or understandings relating to options or derivatives | 
| Full details of any agreement, arrangement or understanding between the person disclosing and any | 
| other person relating to the voting rights of any relevant securities under any option referred to on this | 
| form or relating to the voting rights or future acquisition or disposal of any relevant securities to which | 
| any derivative referred to on this form is referenced. If none, this should be stated. | 
| NONE | 
| Date of disclosure | 10/09/2008 | 
| Contact name | Louise Howard | 
| Telephone number | +44 20 7996 2121 | 
| Name of offeree/offeror with whom connected | BHP Billiton Plc | 
| Nature of connection # | Advisor | 
| FORM 38.5 | 
| DEALINGS BY CONNECTED EXEMPT PRINCIPAL TRADERS | 
| (Rule 38.5 of The City Code on Takeovers and Mergers) | 
| 1. KEY INFORMATION | 
| Name of exempt principal trader | Merrill Lynch International | 
| Company dealt in | Banco Santander SA. | 
| Class of relevant security to which the | Common | 
| dealings being disclosed relate | 
| Date of dealing | 09/09/2008 | 
| 2. DEALINGS | 
| (a) Purchases and sales | 
| Total number of securities | Highest price paid | Lowest price paid | 
| purchased | 
| 4,392,471 | EUR 11.89 | EUR 11.00 | 
| Total number of securities sold | Highest price received | Lowest price received | 
| 3,754,024 | EUR 11.88 | EUR 11.51 | 
| (b) Derivatives transactions (other than options) | 
| Product name, | Short/Long | Number of securities | Price per unit | 
| eg. CFD | 
| Long Swap | LONG | 45,400 | EUR 11.81 | 
| Long Swap | LONG | 34,104 | EUR 11.73 | 
| Long Swap | LONG | 33,459 | EUR 11.70 | 
| Long Swap | LONG | 31,400 | EUR 11.71 | 
| Long Swap | LONG | 30,598 | EUR 11.70 | 
| Long Swap | LONG | 18,089 | EUR 11.70 | 
| Long Swap | LONG | 16,542 | EUR 11.70 | 
| Long Swap | LONG | 3,940 | EUR 11.70 | 
| Long Swap | LONG | 3,850 | EUR 11.67 | 
| Long Swap | LONG | 3,603 | EUR 11.70 | 
| Long Swap | LONG | 550 | EUR 11.66 | 
| Product name, | Short/Long | Number of securities | Price per unit | 
| eg. CFD | 
| Short Swap | SHORT | 61 | EUR 11.70 | 
| Short Swap | SHORT | 11,337 | EUR 11.73 | 
| Short Swap | SHORT | 23,193 | EUR 11.73 | 
| Short Swap | SHORT | 105,362 | EUR 11.78 | 
| (c) Options transactions in respect of existing securities | 
| Product name | Writing, | Number of | Exercise | Type, e.g. | Expiry | Option | 
| selling, | securities under | price | American, | date | money | 
| eg call option | purchasing, | option | European etc | paid/received | 
| varying etc. | per unit | 
| (ii) Exercising | 
| Product name | Number of securities under | Exercise price | 
| eg call option | option | 
| 3. OTHER INFORMATION | 
| Agreements, arrangements or understandings relating to options or derivatives | 
| Full details of any agreement, arrangement or understanding between the person disclosing and any | 
| other person relating to the voting rights of any relevant securities under any option referred to on this | 
| form or relating to the voting rights or future acquisition or disposal of any relevant securities to which | 
| any derivative referred to on this form is referenced. If none, this should be stated. | 
| NONE | 
| Date of disclosure | 10/09/2008 | 
| Contact name | Louise Howard | 
| Telephone number | +44 20 7996 2121 | 
| Name of offeree/offeror with whom connected | Banco Santander SA. | 
| Nature of connection # | Advisor | 
| FORM 38.5(a) | 
| DEALINGS BY CONNECTED EXEMPT PRINCIPAL TRADERS WITH | 
| RECOGNISED INTERMEDIARY STATUS DEALING IN CLIENT- | 
| SERVICING CAPACITY | 
| (Rule 38.5(a) of The City Code on Takeovers and Mergers) | 
| 1. KEY INFORMATION | 
| Name of exempt principal trader | Merrill Lynch International | 
| Company dealt in | BHP Billiton Limited | 
| Class of relevant security to which the | Common | 
| dealings being disclosed relate | 
| Date of dealing | 09/09/2008 | 
| 2. DEALINGS | 
| (a) Purchases and sales | 
| Total number of securities | Highest price paid | Lowest price paid | 
| purchased | 
| 4,230 | AUS 45.31 | AUS 45.31 | 
| Total number of securities sold | Highest price received | Lowest price received | 
| 4,230 | AUS 45.31 | AUS 45.31 | 
| (b) Derivatives transactions (other than options) | 
| Product name, | Short/Long | Number of securities | Price per unit | 
| eg. CFD | 
| (c) Options transactions in respect of existing securities | 
| Product name | Writing, | Number of | Exercise | Type, e.g. | Expiry | Option money | 
| selling, | securities under | price | American, | date | 
| eg call option | purchasing, | option | European etc | paid/received | 
| varying etc. | per unit | 
| (ii) Exercising | 
| Product name | Number of securities under | Exercise price | 
| eg call option | option | 
| 3. OTHER INFORMATION | 
| Agreements, arrangements or understandings relating to options or derivatives | 
| Full details of any agreement, arrangement or understanding between the person disclosing and any | 
| other person relating to the voting rights of any relevant securities under any option referred to on this | 
| form or relating to the voting rights or future acquisition or disposal of any relevant securities to which | 
| any derivative referred to on this form is referenced. If none, this should be stated. | 
| NONE | 
| Date of disclosure | 10/09/2008 | 
| Contact name | Louise Howard | 
| Telephone number | +44 20 7996 2121 | 
| Name of offeree/offeror with whom connected | BHP Billiton Plc | 
| Nature of connection # | Advisor | 
| FORM 38.5(a) | 
| DEALINGS BY CONNECTED EXEMPT PRINCIPAL TRADERS WITH | 
| RECOGNISED INTERMEDIARY STATUS DEALING IN CLIENT- | 
| SERVICING CAPACITY | 
| (Rule 38.5(a) of The City Code on Takeovers and Mergers) | 
| 1. KEY INFORMATION | 
| Name of exempt principal trader | Merrill Lynch International | 
| Company dealt in | Imperial Energy Corporation Plc | 
| Class of relevant security to which the | Common | 
| dealings being disclosed relate | 
| Date of dealing | 09/09/2008 | 
| 2. DEALINGS | 
| (a) Purchases and sales | 
| Total number of securities | Highest price paid | Lowest price paid | 
| purchased | 
| 23,787 | GBP 11.70 | GBP 11.45 | 
| Total number of securities sold | Highest price received | Lowest price received | 
| 103,462 | GBP 11.70 | GBP 11.46 | 
| (b) Derivatives transactions (other than options) | 
| Product name, | Short/Long | Number of securities | Price per unit | 
| eg. CFD | 
| (c) Options transactions in respect of existing securities | 
| Product name | Writing, | Number of | Exercise | Type, e.g. | Expiry | Option money | 
| selling, | securities under | price | American, | date | 
| eg call option | purchasing, | option | European etc | paid/received | 
| varying etc. | per unit | 
| (ii) Exercising | 
| Product name | Number of securities under | Exercise price | 
| eg call option | option | 
| 3. OTHER INFORMATION | 
| Agreements, arrangements or understandings relating to options or derivatives | 
| Full details of any agreement, arrangement or understanding between the person disclosing and any | 
| other person relating to the voting rights of any relevant securities under any option referred to on this | 
| form or relating to the voting rights or future acquisition or disposal of any relevant securities to which | 
| any derivative referred to on this form is referenced. If none, this should be stated. | 
| NONE | 
| Date of disclosure | 10/09/2008 | 
| Contact name | Louise Howard | 
| Telephone number | +44 20 7996 2121 | 
| Name of offeree/offeror with whom connected | Imperial Energy Corporation Plc | 
| Nature of connection # | Advisor | 
Related Shares:
Banco SantanderRio Tinto