Largest Holdings

PANTHEON INTERNATIONAL PARTICIPATIONS PLC

In accordance with UKLA Listing Rule 21.20l(ii), the following list represents
the Company's 10 largest investments as at 30th June 2004 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           
                                                                           
Silver Cup Partners                                Unquoted Fund           
                                                                           
WIN 4 Holdings                                     Unquoted Fund           
                                                                           
Pantheon Global PCC                                Unquoted Fund           
                                                                           
Softbank Capital Partners                          Unquoted Fund           
                                                                           
JLL III                                            Unquoted Fund           
                                                                           
BC European Capital VII                            Unquoted Fund           
                                                                           
Alchemy Plan                                       Unquoted Fund           
                                                                           
Safeguard International Fund                       Unquoted Fund           
                                                                           
Warburg Pincus Equity Partners                     Unquoted Fund