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 31 December 2004 and
where appropriate, any investment with a value greater than 5% of the Company's
gross assets:

Name of company                                 Class of share             
                                                                           
Bowman Partners                                 Unquoted Fund              
                                                                           
Industri Kapital 2000 Fund                      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              
                                                                           
Klee Europe Fund II                             Unquoted Fund              
                                                                           
Arlington Capital Partners                      Unquoted Fund