Portfolio Update

PANTHEON INTERNATIONAL PARTICIPATIONS PLC

In accordance with UKLA Listing Rule 21.20(l)(ii), the following list
represents the Company's 10 largest investments as at 30 September 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           
                                                                           
Alchemy Plan                                       Unquoted Fund           
                                                                           
BC European Capital VII                            Unquoted Fund           
                                                                           
Warburg Pincus Equity Partners                     Unquoted Fund           
                                                                           
Permira Europe II                                  Unquoted Fund           
                                                                           
Safeguard International Fund                       Unquoted Fund