Largest Holdings

PANTHEON INTERNATIONAL PARTICIPATIONS PLC

In accordance with UKLA Listing Rule 21.20(l)(ii), the following list
represents the Company's 10 largest investments and where appropriate, any
investment with a value greater than 5% of the Company's gross assets:

Name of company Class of share

Industri Kapital 2000                               Unquoted Fund          
                                                                           
JLL III                                             Unquoted Fund          
                                                                           
WIN 4 Holdings                                      Unquoted Fund          
                                                                           
Pantheon Global PCC                                 Unquoted Fund          
                                                                           
Softbank Capital Partners                           Unquoted Fund          
                                                                           
BC European Capital VII                             Unquoted Fund          
                                                                           
DLJ Merchant Banking Partners II                    Unquoted Fund          
                                                                           
Warburg Pincus Equity Partners                      Unquoted Fund          
                                                                           
Alchemy Plan                                        Unquoted Fund          
                                                                           
Permira Europe II                                   Unquoted Fund          

5 January 2004