Pantheon Code of Ethics/Conduct and Registrations

The continued success of Pantheon depends upon its relationships with its clients, investors and portfolio fund managers and its excellent reputation as an organization with integrity and ethical conduct in all of its dealings. Pantheon is committed to maintaining its tradition of ethical conduct and, to this end, Pantheon requires high ethical behaviour as well as strict adherence to applicable legal and regulatory requirements from its Associates.

Pantheon is subject to a Global Code of Ethics (“Code”) which describes important policies concerning the personal conduct responsibilities of Pantheon Associates of the Pantheon Group1 that are intended to address certain ethical, legal and regulatory requirements. Pantheon Associates are required to read and become knowledgeable about the Code and adhere to both the principles and specifics of these policies, as well as all applicable laws, regulations and rules.

Website Terms and Conditions of Use

Please read the following Important Legal Information and Terms and Conditions (the “Terms and Conditions”) prior to using this website. Access to this website is provided by the Pantheon Ventures (UK) LLP, which has approved and published this website on behalf of the Pantheon Group. Pantheon Group refers to Pantheon Holdings Limited, Pantheon Ventures, Inc., Pantheon Capital (Asia) Limited, Pantheon Ventures (UK) LLP, Pantheon Ventures (US) LP, Pantheon Ventures (Singapore) Pte Ltd, Pantheon Ventures (HK) LLP, Pantheon Ventures (Ireland) DAC and each of their respective subsidiaries and subsidiary undertakings. By accessing or using this site, you acknowledge that you have read and understood the Terms and Conditions and have agreed to and accepted, without limitation or qualification, these Terms and Conditions. Pantheon reserves the right to change these Terms and Conditions from time to time without notice, as it deems necessary and to alter or delete materials from this website at any time at its discretion. It is your responsibility to review the Terms and Conditions and to make sure you understand and comply with them. Your compliance with the Terms is an ongoing condition to your use of this website, and you may not use it if you are not prepared to comply with all of the Terms and Conditions.

These Terms and Conditions constitute the entire agreement between you and Pantheon and govern your use of this website and any services offered through this website. This agreement supersedes any prior terms of use or other agreements concerning the subject matter hereof between you and Pantheon. These Terms and Conditions and the relationship between you and Pantheon shall be governed by, and construed and enforced in accordance with, the laws of England & Wales without regard to its conflict of law provisions that might cause the application of the laws of another jurisdiction. You agree to submit to the personal and exclusive jurisdiction of English Courts for the resolution of any disputes arising out of or relating to these Terms and Conditions or this website. The failure by Pantheon to exercise or enforce any right or provision of these Terms and Conditions shall not constitute a waiver of such right or provision, and no waiver shall be enforceable unless in writing and signed by the party against whom enforcement is sought. If any provision of these Terms and Conditions is found by a court of competent jurisdiction to be invalid, unlawful, void or unenforceable, then such provision shall be severable without affecting the enforceability of all remaining provisions, which shall remain in full force and effect.

Legal and Regulatory Information about Pantheon

Pantheon Ventures Inc. is registered as an investment adviser with the U.S. Securities and Exchange Commission (SEC No.: 801-32850). Pantheon Ventures (US) LP is registered as an investment adviser with the U.S. Securities and Exchange Commission (SEC No.: 801-71327). Pantheon’s office in Bogota is a representative office of Pantheon Ventures (US) LP.

Pantheon Ventures (UK) LLP is authorised and regulated by the Financial Conduct Authority (“FCA”) in the United Kingdom (FCA Reference Number 520240). In accordance with FCA MIFIDPRU Pantheon Ventures (UK) LLP provides information about its Risk Management Framework, Financial Position, Capital Planning and Remuneration in its MIFIDPRU8 Disclosure which can be accessed here.

Pantheon Ventures (UK) LLP is also an Exempt Reporting Advisor and subject to reporting and filing requirements with the US SEC. Pantheon Ventures (UK) LLP is registered with the Australian Securities & Investments Commission (ASIC) and provides services under an exemption as a Foreign Financial Services Provider in reliance on the ASIC Class Order [CO 03/1099] for UK regulated financial service providers.

Pantheon Ventures (Ireland) DAC is a limited liability designated activity company, incorporated in Ireland. It is authorised by the Central Bank of Ireland in Ireland, with reference number C182965. Its head office is at Ella House, 39-43 Merrion Square East, Dublin 2, Ireland, D02 NP96 and it is registered with the Companies Registration Office in Ireland with company registration number 630487. Pantheon Ventures (Ireland) DAC carries on certain activities in the United Kingdom from the London office of Pantheon Ventures (UK) LLP and in carrying on those activities is an appointed representative of Pantheon Ventures (UK) LLP, which is authorised and regulated by the Financial Conduct Authority in the United Kingdom.

Click here to access Pantheon Ventures (Ireland) DAC’s remuneration disclosure in respect of the period from 1 January to 31 December 2023.

Pantheon Ventures (Asia) Limited is registered as a Type II Financial Instruments Business and Investment Advisory and Agency Business Operator under the registration entry “Director General of the Kanto Local Finance Bureau (Financial Instruments Business Operator) No. 3138” under the Financial Instruments and Exchange Act of Japan (the “FIEA”) and a regular member of the Type II Financial Instruments Firms Association of Japan and Japan Investment Advisers Association.

Pantheon Ventures (Guernsey) Limited, together with a number of other Pantheon entities incorporated in Guernsey, are regulated by the Guernsey Financial Services Commission (GFSC).

Affiliation with Pantheon Securities, LLC

Notice of Investor Education and Protection Information Pursuant to FINRA Rule 2267

Interests in Pantheon funds are distributed by Pantheon Securities, LLC in the U.S. and Canada, which is registered as a broker-dealer with the U.S. Securities and Exchange Commission (“SEC”) and is a member of the Financial Industry Regulatory Authority (“FINRA”) and the Securities Investor Protection Corporation (“SIPC”). Pantheon Securities, LLC is a wholly-owned subsidiary of Pantheon. Please refer to the FINRA’s website (www.finra.org) and/or FINRA BrokerCheck (www.finra.org/brokercheck), or Hotline Number (800) 289-9999) for more information about FINRA and its member organizations.

FINRA BrokerCheck is a resource tool to help investors check the professional background of current and former FINRA-registered securities firms and brokers. Features of FINRA BrokerCheck include:

• Search capabilities for both a broker and brokerage firm
• Online delivery of a report on a broker or brokerage firm
• Explanatory information to help investors better understand the content, context and source of the information provided
• links to additional resources and tools

The information made available through FINRA BrokerCheck is derived from the Central Registration Depository (CRD®), the securities industry online registration and licensing database, as reported on industry registration/licensing forms brokers, brokerage firms and regulators complete. More detailed information regarding FINRA BrokerCheck is contained in an investor brochure which is available via the FINRA website.

Important Information About Procedures for Establishing a Relationship with Pantheon Securities

To help the government fight the funding of terrorism and money laundering activities, Federal law requires all financial institutions to obtain, verify, and record information that identifies each customer of the Firm. What this means for you: When you establish a customer relationship with us, we will ask for your name, address, date of birth, and other information that will allow us to identify you. We may also ask to see your driver’s license, passport, or other identifying document.

Pantheon Order/Best Execution Policy

As a part of our arrangements for ensuring that we comply with this requirement, we have established and adopted procedures to implement the Order/Best Execution Policy, conduct reviews to monitor compliance with the firm’s policy and amend or update the firm’s policy, as appropriate.

Shareholder Rights Directive II (Directive 2007/36/EC) (SRDII)

SRD II seeks to promote shareholder engagement and is part of a series of EU wide measures intended to improve stewardship and corporate governance. The Directive aims to encourage effective stewardship, in part, by improving transparency about how stewardship is exercised across the institutional investment community. Underpinning it is an assumption that greater transparency will make effective stewardship a differentiating factor across firms and that this will encourage higher standards. Among other things, the Directive imposes requirements on asset owners and asset managers to develop and publicly disclose (on a comply or explain basis) an engagement policy. It also requires them to disclose annually how this policy has been implemented.

Pantheon has not adopted an engagement policy (pursuant to Article 3g of SRDII) on the basis that it considers SRD II is largely inapplicable to Pantheon’s investment strategies which are focused on investment in private, illiquid assets. Pantheon does have policies regarding [proxy voting as well as] corporate responsibility and environmental, social and governance (ESG) issues and considers that the principles behind this approach are aligned with those of SRD II. This includes the, monitoring of portfolio investments, exercising of voting rights attached to portfolio investments and engagement with managers of portfolio investments.

Business Continuity Plan (“BCP”) Summary

Pantheon Securities, LLC (“Firm”) has developed a Business Continuity Plan (“BCP”) to address responses to events that cause or have the potential to cause a significant business disruption (“SBD”). As the timing and impact of disasters and disruptions is unpredictable, the Firm will have to be flexible in responding to actual events as they occur. With that in mind, we are providing you with this information regarding our BCP.

The Firm’s BCP addresses: data backup and recovery; mission critical systems; financial and operational assessments; alternative communications with customers, employees, and regulators; alternate physical location of employees; critical supplier, contractor, bank and counterparty impact; and regulatory reporting.

The Firm maintains a BCP that provides a course of action for the assessment of an SBD to Firm business and for the continuation of Firm business following such an event. During such an event, the BCP will facilitate the re-establishment and continuation of business processes pursuant to the BCP. The BCP establishes the evaluation of the disruption, institution of the appropriate plan of action, and coordination of recovery efforts.

In the event of an SBD, the Firm intends to continue to maintain business relations with its clients and counterparties, as applicable and to the extent possible. Given the nature of the business and our disaster recovery testing results, we anticipate being able to recover critical systems from most disasters within 4 to 8 hours and completely recover within 1 to 2 weeks. In the event that an SBD affects the operation of our current locations, the affected employees and associated persons of the Firm will conduct business remotely using technology and training provided to them in advance. In addition, the Firm has implemented backup storage and computing facilities to facilitate business recovery.

In the event that business operations are affected, clients of the Firm may reach an employee of the Firm by contacting us at (212) 205-2000.

The BCP is designed to address SBDs of varying scope including, but not limited to:

• Firm-only business disruptions;
• Disruptions to the Firm’s main office, branches office(s), or non-branch office location(s) in which business is conducted;
• Disruptions to a business district in which the Firm’s business is conducted;
• City-wide business disruptions;
• Regional disruptions; and
• National disruptions.

Recovery facilities exist for the continuation of the Firm’s business, and alternative means are available for the dissemination of information to employees, associated persons, and clients. The BCP serves as a guide that addresses how the Firm will continue to conduct business during each of the above scenarios, to the extent that is possible.

It is the Firm’s intention to minimize the recovery time necessary to resume operations. The Firm conducts regular testing of the recovery of its backup facilities and systems in order to ensure they are secured and accessible within a reasonable time following an SBD. Clients should be assured they will have prompt access to the Firm through adequate backup systems.

The BCP is subject to modification based on changing circumstances and assessment of need.

If you have questions about our business continuity planning, you can contact us at (212) 205-2000.

Status of Information

The information on this website (including any portion of this website available only to investors) does not constitute or form part of an offer to sell or an invitation to purchase or subscribe for shares, securities or any other form of investment, neither is it an offer or solicitation to enter into any agreement for the provision of investment services or to participate in any particular trading or investment strategy, nor may it or any part of it form the basis of, or be relied upon in connection with, any contract relating thereto. Pantheon does not give or offer to give investment advice or any investment services through this website. The information on this website is provided for general information purposes only. The information on these pages is intended solely for the benefit of third party issuers and those seeking information about relevant investment strategies. The information is not comprehensive, is not intended to constitute any recommendation to acquire or dispose of any securities or apply for or use any investment related service or product and does not constitute investment, legal, tax or other advice or opinion regarding the specific investment objectives or financial situation of any person. Any investments, securities or strategies referred to on this website may not be suitable for particular investors depending on their specific investment objectives and financial situation.

Jurisdictional Restrictions

This website is published by Pantheon Ventures (UK) LLP and to the extent that this website is directed at users in the United Kingdom, it is directed only at, the following persons: (a) persons who have professional experience in matters relating to investments and who are “Investment Professionals” as defined in Article 14 of the Financial Services and Markets Act 2000 (Promotion of Collective Investment Schemes) (Exemptions) Order 2001 (the “CIS Exemptions Order”), (b) persons who are high net worth companies, unincorporated associations, partnerships or trusts falling within any of the categories of persons described in Article 22 of the CIS Exemptions Order, [ and (c) any other persons to whom it may otherwise lawfully be directed (together, “Relevant Persons”). This communication is not directed at, or acted or relied upon by, any person in the United Kingdom who is not a Relevant Person as defined above. Any investment or investment activity or service to which this website relates is available only to persons in the United Kingdom who are Relevant Persons and who are also professional clients (as defined under FCA rules) and will be engaged in only with such persons. In any other jurisdiction, the information on this website is intended only for persons to whom such information can be lawfully communicated without any approval being obtained or any other action being taken to permit such communication where approval or other action for such purpose is required, as there may be legal requirements in various countries and jurisdictions which may restrict the information that can be accessed. The information on this website is not directed at and is not for use by any other person. Persons who obtain information from this website should therefore inform themselves about and observe any restrictions imposed in the jurisdiction in which this website is accessed.

Website Security

You may not violate the security of this website or attempt to do so. Any actual or attempted tampering with any part of this website, provision of untruthful or inaccurate information, misrepresentation of your identity, or conduct of fraudulent activities on or through this website is prohibited. Without limiting the generality of the foregoing, you may not do anything that could interfere with the functioning of this website, restrict or inhibit others from accessing or using it, or result in the transmission of a virus, worm, time bomb or other harmful component.

Third Party Websites, Links and Framing prohibited

Without the prior written consent of Pantheon, linking to Pantheon’s website (www.pantheon.com) or any Pantheon content or the framing of Pantheon’s content in any way is expressly prohibited. Any links which exist on Pantheon’s website do not constitute an endorsement of that entity or product and Pantheon accepts no liability for the accuracy or safety of the content therein.

This website may also contain data or information obtained from or links to websites operated or controlled by, or be accessed from links provided by, persons other than Pantheon. Any such data, information and links are for information purposes only. Pantheon makes no warranties or representations of any kind as to the accuracy, currency, or completeness of any such data or information or of any material or information accessed or obtained through any such links and has not and will not review or update such data, information or material. Use of any such data, information or material is at your own risk. Pantheon accepts no responsibility for such data, information or material and shall have no liability for any damages or injuries of any kind arising from the use or reliance on any such data, information or material.

Cookie Policy

In addition, Pantheon’s website may store “cookies,” related to identifying a user’s computer. You are responsible for your own “cookie” preferences. Please note that changing “cookie” preferences may affect your ability to access Pantheon’s website and full functionality may be absent without the use of cookies. A particularly relevant manner in which we use cookies is to record when a visitor has seen a policy such as this one, or provided consent, such as consent to our terms and conditions. Cookies also provide basic functional purposes. This allows the website to recognize your visit from those of other users of the website. You can find more information at www.allaboutcookies.org and www.youronlinechoices.eu. If you do not want to receive cookies, you can modify your browser so that it notifies you when cookies are sent to it or you can refuse cookies altogether. You can also delete cookies that have already been set. If you wish to restrict or block web browser cookies which are set on your device then you can do this through your browser settings. By continuing to use this website, you consent to Pantheon’s use of cookies as described above.

Modern Slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labor and human trafficking all of which have in common the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain. The UK Modern Slavery Act (“the Act”) came into force on 29th October 2015. It
created additional criminal offences for those committing such acts and had the intention of seeking to establish transparency in supply chains in modern commercial organizations. Section 54 of the Act provides that a commercial organization which supplies goods or services and has a prescribed turnover (currently £36 million) shall establish a policy on how to combat modern slavery.

Set forth below are a policy statement and an overview of the steps taken by Pantheon Ventures (UK) LLP (“PV (UK) LLP” or “Pantheon”) for the financial year ending 31 December 2023 to mitigate the risk of modern slavery taking place in its business or supply chains.

PV (UK) LLP is a member of the Pantheon Group. The Pantheon Group provides primary fund investment, secondary fund investment, and direct co-investment strategies across the private equity, real asset, infrastructure and credit asset classes and other innovative investment solutions, to a globally diverse range of clients and investors, directly through customised separate account programmes or indirectly through funds managed by a member of the Pantheon Group. In the UK, Pantheon Group’s business is carried on by PV (UK) LLP.

Click here to read the full statement

SRD II seeks to promote shareholder engagement and is part of a series of EU wide measures intended to improve stewardship and corporate governance. The Directive aims to encourage effective stewardship, in part, by improving transparency about how stewardship is exercised across the institutional investment community. Underpinning it is an assumption that greater transparency will make effective stewardship a differentiating factor across firms and that this will encourage higher standards. Among other things, the Directive imposes requirements on asset owners and asset managers to develop and publicly disclose (on a comply or explain basis) an engagement policy. It also requires them to disclose annually how this policy has been implemented.

Pantheon has not adopted an engagement policy (pursuant to Article 3g of SRDII) on the basis that it considers SRD II is largely inapplicable to Pantheon’s investment strategies which are focused on investment in private, illiquid assets. Pantheon does have policies regarding [proxy voting as well as] corporate responsibility and environmental, social and governance (ESG) issues and considers that the principles behind this approach are aligned with those of SRD II. This includes the, monitoring of portfolio investments, exercising of voting rights attached to portfolio investments and engagement with managers of portfolio investments.

Pantheon Ventures (Asia) Limited
金融商品取引業者　関東財務局(金商)第3138号
加入協会/一般社団法人第二種金融商品取引業協会、一般社団法人日本投資顧問業協会

適格機関投資家等特例業務に関する公衆縦覧について
下記の適格機関投資家等特例業務の届出者(ジェネラル・パートナー)による公衆縦覧につきましては、ファンドのジェネラル・パートナーから委託を受けて金融商品取引法第63条第6項及び第63条の4第3項に定める文書を弊社に据え置き、公衆の縦覧に供しております。尚、Pantheon Ventures (Asia) Limitedが適格機関投資家等特例業務を行うものではありません。

公衆の縦覧に供する場所
Pantheon Ventures (Asia) Limited
東京都千代田区丸の内1丁目4-1丸の内永楽ビルディング22階
お問い合わせ先：tokyo@pantheon.com

This notice (the “Notice”) is provided by each of the entities listed in the Appendix under this link (together “Pantheon”, “us” or “we”) as data controller. This Notice is addressed to any natural person who is any of the following: a client of Pantheon Group or a direct or indirect investor in any fund managed or advised by Pantheon Group1 (a “Pantheon Fund”), or a member, partner, shareholder, beneficial owner, officer, director, employee or other representative of any client of Pantheon Group or of any direct or indirect investor in any Pantheon Fund, including any prospective client or investor (referred to as “you” in this Notice) whose personal information Pantheon collects and controls in the conduct of its business. If you are a non-natural person that provides us with personal information on individuals connected to you for any reason in relation to your investment with us, this Notice will be relevant for those individuals and you should provide a copy of this Notice to such individuals or otherwise advise them of its content.

This Notice provides information regarding your personal information (defined as “personal data” under the Privacy Laws (defined below)) and describes the basis on which we process your personal information, for what purposes, your privacy rights under applicable privacy laws including without limitation, where applicable, General Data Protection Regulation (Regulation (EU) 2016/679) (“EU GDPR”), the EU GDPR as it forms part of the laws of England and Wales, Scotland and Northern Ireland by virtue of section 3 of the European Union Withdrawal Act 2018 (“UK GDPR”), the UK Data Protection Act 2018, the Privacy and Electronic Communications (EC Directive) Regulations 2003, Data Protection Law (Revised) of the Cayman Islands (“DPL“), the Data Protection (Bailiwick of Guernsey) Law 2017, the California Consumer Privacy Act (“CCPA”), the California Privacy Rights Act (“CPRA”) and applicable US and non-US privacy and data protection laws (the “Privacy Laws”) and how we protect your personal information. Maintaining your privacy is important to us and we hold ourselves to the highest standards in its safekeeping and use. We have developed policies designed to protect the confidentiality, while allowing the needs of investors and clients to be served. We do not sell any personal data and have not sold any personal data in the past.

The information we collect

In the conduct of our business, we may obtain personal information about you in connection with your existing or proposed appointment or engagement of Pantheon or existing or proposed investment in a Pantheon Fund (any such person being a “Pantheon Client”), including without limitation your name, role/position/title and area of responsibility, address and other contact details, and certain identifying information such as date of birth address and social security number, tax or other identification number. If you deal with Pantheon in your individual capacity (e.g., as an individual client), or as a settler/trustee/beneficiary of a trust, or as an owner or a principal of a company or other investment vehicle established to invest on your behalf or on behalf of your family, we may additionally collect information about your income, assets and other financial information, including asset situation, investment experience and objectives, risk tolerance as well as your age, occupation and marital status. This information may come directly from public sources such as governmental authorities, public directories and screening or background checking tools, or from you such as application, subscription or other forms or material completed or supplied by actual or prospective Pantheon Clients, other written, electronic or verbal correspondence which relate to transactions by or on behalf of a Pantheon Client as well as financial information relating to any such person’s investment in a Pantheon Fund or any portfolio investments, such as capital account balance, contributions, income allocations and distributions. We may also collect personal information provided by you in calls which are recorded by us, as required by applicable laws.

We may also collect special categories of personal data (as defined in the EU GDPR and UK GDPR and including health, disability and religious or ethnicity information) where provided by you, with your consent, such as disability information or religious data for purposes required by you such as scheduling of meetings or access to Pantheon or Pantheon Group premises.

How we use information that we collect

We collect your personal information to fulfil our contractual or legal obligations and/or to pursue the legitimate interests of Pantheon. Pantheon Group or a Pantheon Fund to operate its businesses. From time to time, we may need to process your personal information on other lawful bases, including: (i) with your consent; (ii) if it is necessary to protect your vital interests; or (iii) it is necessary for a task carried out in the public interest. If you have provided special categories of personal data to us to enable us to respond to certain requests by you such as access requests or scheduling of meetings or similar requirements, we do so with your consent.

We process your personal information for the following purposes: (i) for compliance with legal and regulatory requirements such as regulations aimed at prevention of money laundering or terrorist financing or “Know your Customer” requirements, as well as to verify the status and / or eligibility of Pantheon Clients for funds or services offered by Pantheon, and for determination of the suitability of such funds or services for Pantheon Clients and for compliance with tax reporting requirements; (ii) for purposes of reporting to, or communicating with, Pantheon Clients, and their representatives, advisors and agents, concerning their existing or prospective investment in Pantheon Funds or existing or prospective appointment or engagement of Pantheon or Pantheon Group entities consistent with our obligations to such Pantheon Clients; (iii) to carry out transactions on behalf of Pantheon Funds and Pantheon Clients properly and smoothly, including in connection with our investment activities, including investment due diligence or investment monitoring activities or in response to “Know your Customer” requirements of counter-parties; (iv) to perform the obligations of Pantheon, Pantheon Group entities or Pantheon Funds under applicable agreements (e.g., partnership agreements and/or subscription agreements); (v) the ongoing administrative, management, accounting, reporting and other processes and communication required to operate the business of Pantheon Funds; (vi) to research and develop financial products and services; (vii) to keep Pantheon Clients informed about the business of Pantheon and Pantheon Group entities generally, including offering opportunities to make investments; (vii) to facilitate our internal business operations, including without limitation assessing and managing risk; (viii) in connection with litigation, investigations, regulatory or governmental enquiries or for other legal or regulatory purposes involving Pantheon, Pantheon Funds or Pantheon Clients; (ix) to protect our businesses and the security of our systems, which processing may be in connection with the monitoring of communications (to the extent permitted by the Privacy Laws and other applicable laws); and (x) for other legitimate business interests.

A failure to provide the personal information requested to fulfil the purposes described in this Notice may result in Pantheon, Pantheon Group entities or Pantheon Funds being unable to provide the services offered by them.

In addition, we may, either with your consent or where we have identified a legitimate interest in doing so (and to the extent permitted by law), process your personal information in order to communicate with you, on behalf of the organization for whom you work or directly for yourself, for certain marketing purposes related to our business. In this event, we may provide additional information that we believe may be of interest, including about funds or services, news updates, research or market commentary, conferences, or events offered by or in conjunction with Pantheon. You have the right to unsubscribe from these communications by emailing infosec.privacy@pantheon.com or by following the instructions in any such communication, e.g., by clicking on the link to unsubscribe or by writing to the Data Protection Officer at the address provided below.

The Disclosure of your Information

Within the Group: We may share your personal information with Pantheon Group entities, including those listed in the Appendix and also with Pantheon Funds for any of the purposes set forth above. Pantheon Group entities and Pantheon Funds, in turn, are not permitted to share your information with other non-affiliated entities, except as described herein or otherwise permitted by the Privacy Laws or other applicable laws.

Outside the Group: We may share your personal information with non-affiliated third parties for any of the purposes set forth above. By way of example, we share your personal information with:

• Service providers (e.g., attorneys, auditors, accountants, tax advisers, administrators, custodians, depositaries, distribution managers and brokerage firms, AML service providers, tax information exchange service providers, event organizers or other agent, adviser or service provider of any Pantheon Fund or Pantheon Client). As is common in the industry, non-affiliated third party companies may from time to time be used to provide certain services, such as administration services, tax compliance services, reporting, account statements and other information, organizing events, conducting research on client satisfaction and gathering shareholder proxies. These companies may have access to your personal information but are permitted to use the information solely to provide the specific service or as otherwise permitted by law.
• Other counter-parties, including any portfolio fund, any vendor, any lender or any of their respective managers, general partners or investment advisers or administrators, or any of their respective agents or representatives or any affiliate of any of the foregoing. For example, we may share personal information with a prospective portfolio fund of any Pantheon Fund or Pantheon Client in order to respond to the anti-money laundering enquiries of such portfolio fund.

We may also share your personal information with law enforcement agencies and applicable regulators and tax authorities.

Transfers to Non-Equivalent Countries. Pantheon, Pantheon Group entities and the Pantheon Funds may transfer your personal data to a Non-Equivalent Country (as defined below) in order to fulfill the purposes described in this Notice and in accordance with the Privacy Laws, including where such transfer is a matter of contractual necessity, and to implement any requested pre-contractual measures. For information on the safeguards applied to such transfers, please contact infosec.privacy@pantheon.com. “Non-Equivalent Country” shall mean a country or territory other than (i) a member state of the European Economic Area; (ii) the United Kingdom; or (iii) a country or territory which has at the relevant time been decided by the European Commission, the Government of the United Kingdom or such other applicable data protection authority or regulator of the country in which the data exporter is located (as applicable) in accordance with the Privacy Laws to ensure an adequate level of protection for personal data.

Security

We take seriously the obligation to safeguard your personal information. We maintain physical, electronic, and procedural safeguards to protect against unauthorized access to your personal information in our possession or under our control. We endeavor to restrict access to such personal information about you to those members, officers, employees and other workers of Pantheon and service providers who need access to that information. All of our employees and service providers are required to maintain the confidentiality of all nonpublic personal information. Pantheon Group has appointed a Data Protection Officer (whose contact details are provided below) with overall responsibility for safekeeping of personal data and implementation of this policy within our Group.

Changes to this Notice

We may change this Notice from time to time. The latest version will be posted on our website.

Updating your details

If any of the information that you have provided to us changes, for example if you change your email address, or it is found to be inaccurate, please let us know by sending an email to infosec.privacy@pantheon.com, by calling toll-free (within the U.S. only) (844) 927-1475, or by writing to the Data Protection Officer at the address provided below.

Your rights

You have certain rights relating to the personal information we hold about you in accordance with and subject to applicable Privacy Laws to: (i) check whether we hold personal information about you and to access such data (in accordance with our policy); (ii) request the correction/rectification of personal information about you that is inaccurate or incomplete; (iii) have a copy of the personal information we hold about you provided to you or another controller where technically feasible; (iv) request the erasure of your personal information; (v) request the restriction of processing concerning you; (vi) data portability; (vii) object to processing for direct marketing purposes or based on our legitimate interests; (viii) withdraw any consent given in relation to the processing of the personal information we hold about you, at any time2; (ix) not be subject to automated decision-making; and (x) be notified of rectification, erasure and restrictions. To do so, please send your request by email to infosec.privacy@pantheon.com, by calling toll-free (within the U.S. only) (844) 927-1475, or by writing to the Data Protection Officer at the address provided below. If you submit a request in relation to the access or erasure of your personal information, you will be required to verify your identity by answering certain questions. You will not be discriminated against for exercising these rights. You are required to ensure the personal information we hold about you is up-to-date and accurate and you must notify us of any changes to the personal data you provided to us in, for example in information supplied in relation to an investment in the applicable Pantheon Fund. If you provided consent for us to use your personal information, including for marketing purposes, you have the right to withdraw consent at any time and we will process this withdrawal promptly (unless otherwise required by applicable law). To withdraw consent, please email infosec.privacy@pantheon.com, call toll-free (within the U.S. only) (844) 927-1475, or write to the Data Protection Officer at the address provided below.

Data Retention

We retain your personal information for a period of at least five years from the date on which the relevant business relationship, for which purpose such personal data was provided, has ended (or if later the date on which the last transaction was completed or the last entry to the record was made). Thereafter, Pantheon will delete (or otherwise erase, de-identify or pseudonymise or equivalent) any such personal data except as required or permitted by applicable law or regulation.

What if I have a question?

Please email infosec.privacy@pantheon.com, call toll-free (within the U.S. only) (844) 927-1475, or write to the Pantheon Data Protection Officer c/o Pantheon Ventures (UK) LLP, 10 Finsbury Square, 4th Floor, London EC2A 1AF if you have any questions about our privacy notice. You may also make a complaint, in accordance with applicable Privacy Laws to a supervisory authority. Our UK supervisory authority is the Information Commissioner’s Office our Irish supervisory authority is the Data Protection Commission, the Guernsey supervisory authority is the Office of the Data Protection Commissioner, and the Cayman Islands supervisory authority is the Office of the Ombudsman of the Cayman Islands.

¹Pantheon Group means Pantheon Ventures Inc. and AMG Plymouth UK Holdings (1) Limited and their respective subsidiaries and subsidiary undertakings and specifically includes the affiliates listed in the Appendix as amended from time to time.

²For residents of California only, as required under the CCPA and CPRA, you may directly request limitations on how we may use and retain personal and sensitive information by email to infosec.privacy@pantheon.com, noting “Do Not Sell or Share my Personal Information” or “Limit the Use of My Sensitive Personal Information.” Sensitive personal information is defined under the CCPA and CPRA as personal information that may reveal: an individual’s social security, driver’s license, state identification card, or passport number; account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account; precise geolocation; racial or ethnic origin, religious or philosophical beliefs, or union membership; contents of mail, email, and text messages unless the business is the intended recipient of the communication; genetic data.; or biometric information.

Pantheon Ventures (UK) LLP/Pantheon Ventures (US) LP/Pantheon Ventures (Ireland) DACH

The aim of this Worker Privacy Notice (“Notice”) is to inform the current, former and prospective Partners, employees, and any other workers, contractors, consultants or other self-employed individuals performing work or providing services on behalf of Pantheon Ventures (UK) LLP, registered in England and Wales under company number OC352463 with registered office at 4th Floor, 10 Finsbury Square, London, England, EC2A 1AF or Pantheon Ventures (US) LP, with offices at 555 California Street, Suite 3450, San Francisco, CA 94104 USA (collectively, the “Company” or “we” or “us”), or Pantheon Ventures (Ireland) DAC, with offices at Sobo Works, Windmill Lane, Sir John Rogerson’s Quay, Dublin, D02 K156, as applicable, (each, the “Company” or “we” or “us”). This Notice is provided by the relevant Company as data controller and gives information on the collection, use, disclosure, transfer, and other processing of their individually identifiable information (“Personal Data”), and your privacy rights under applicable data protection and privacy laws, including, where applicable, under the General Data Protection Regulation (Regulation (EU) 2016/679) (“EU GDPR”), the EU GDPR as it forms part of the laws of England and Wales, Scotland and Northern Ireland by virtue of section 3 of the European Union Withdrawal Act 2018 (“UK GDPR”), the UK Data Protection Act 2018, the California Consumer Privacy Act (“CCPA”), the California Privacy Rights Act (“CPRA”) and applicable US and non-US privacy laws (the “Data Privacy Laws”).

Personal Data

Throughout the course of your employment or engagement with the Company, we collect and process certain Personal Data about you. We collect and process your Personal Data (a) for purposes that are required by applicable law, regulations, or other contracts, (b) to allow the Company to fulfil its business needs and legal obligations, and (c) to maintain the employment or business relationship. The Personal Data we collect and process includes the following categories (where applicable to the employment or engagement):

• Contact information: such as full name, including title, name at birth and preferred name, work address, work phone number, work fax number, work email address, work mobile phone number, office e-mail address, office phone number, employment location, job title and job title code, employee IDs.
• Master data and qualified HR data: such as job function, contractual details, education information (including grades and fee repayment obligations), CV/résumé, nationality, passport information, residency status, date of birth, birth city and country, gender, marital status, relationship information, primary language, language skills, visa type and information (work permit/business/etc.), home address and home telephone number, personal mobile phone number (including mobile phone or device billing and usage records), emergency contact information (including details of immediate family), next of kin information, maternity protection information including notification date of pregnancy, expected date of delivery, actual date of delivery and type of birth, paternity leave, adoption information, employment location, employment action (hire/rehire/termination), reason for employment action (hire/rehire/termination/leave), employee classification, employment status, type of contract, hire date, term and related contract information, power of attorney information, information on loaned company property, probation period information, notice period, job classification, information and status on global assignments, full time/part time status, department, region, market, project and project allocation, cost centre, manager, travel details, employee expenses, company training history, performance rating history, competencies, development areas, work schedule and time worked, attendance and substitution information, leave of absence information (holidays, sick leave, maternity/paternity/adoption and parental leave, bereavement, miscellaneous leave (e.g., volunteering days)) including payment and entitlement information, all personal data required to provide data subjects (1) access to company computer systems and networks and (2) tools and devices to electronically communicate within the Pantheon Group¹, including but not limited to IP address, geolocation/geo-tracking data, and user login name.
• Payroll data: such as national ID number/social security number, pension contribution information, banking data necessary to make payments to data subject, compensation information, dependent details (address, date and place of birth), end of service payment and accruals, base salary, annual salary, wage type, salary deductions, currency, garnishment, employee’s wage tax (withheld by the employer), bonus compensation, other variable compensation, other leave compensation, not taken holidays compensation, all company paid expenses, benefits and benefits in kind, health benefits, travel allowances, commuting allowances and information, adjustments and salary reductions, third party payments.
• Other financial information: such as information relating to investments in funds managed or advised by members of the Pantheon Group or equity investments in the Pantheon Group itself or other carried interest, deferred compensation or incentive plans of the Pantheon Group, including full name, plan information, award value information, settlement information, tax obligation, exercise type, country, amount and price, bank information details, payment beneficiary.
• Performance, Training and Discipline information: such as work experience, education, accomplishments, mobility, career goals and type, development plans, training and competence records, performance (including targets, achievements and appraisals), potential assessment information, succession plan information, talent review meeting information, notes of disciplinary and grievance meetings; disciplinary/poor performance warnings; etc.
• Job applicant information: such as candidate details, status, ranking, email address, address, current employer, job history, work and corporate title, education, qualifications, references, criminal record checks, desired function and work location, licenses, certificates, work experience, resume information, public searches, including of social media.
• Health information: such as illness and accidents information, health, disability information, insurance and saving plan information, including deductions, eligibility and coverage, enrolment plan, data on sick leave and disability information. This type of Personal Data (known as sensitive or special categories of data) will only be processed where required for the relevant purposes.
• Health & Safety Risks; such as where desk assessments, pre-natal and ante-natal maternity risk assessments, risk assessments related to the workplace to accommodate disabled persons/employees or employees returning from long term sick leave, all of which are required to be made for medical reasons. This type of Personal Data (known as sensitive or special categories of data) will only be processed where required for the relevant purposes.
• Compliance information: information required for regulatory or compliance purposes, such as information relating to political donations, outside business activities and information relating to personal account dealing.
• Security: details for pass cards; CCTV images; voice recordings etc.
• Health and safety records: information relating to health and safety in the workplace, accidents and near misses.
• Equal opportunities monitoring information: such as your ethnicity, religion, gender and sexual orientation.

Biometric information: such as fingerprint password information stored on a Company-issued phone or other device. Sources of Personal Data

We may obtain Personal Data from the sources listed below:

• Directly from you, such as through your data input into our Human Resources or Compliance systems, the application process or via other forms or information you provide to us in connection with your employment or engagement with us (job application, employment contract, benefits application forms, personal details form, internal resume/management profile, emergency contacts, etc.);
• through your activities in the course of your employment, such as through your performance evaluations;
• through monitoring of your activities, including IT monitoring of emails and use of our IT systems, equipment and our devices as well as internal CCTV, where applicable, and recordings of certain external telephone calls with third parties; and
• from third parties, including references and other background screening checks, former employers, and employment recruitment agencies, subject to the requirements of applicable law.

Information about dependents/contacts

If you provide us with Personal Data about members of your family and/or dependents or beneficiaries (e.g., for emergency contact or benefits administration purposes), it is your responsibility to inform them of their rights with respect to such information. You also are responsible for obtaining the explicit consent of these individuals (unless you can provide such consent on their behalf) to the processing (including transfer) of that Personal Data for the purposes set out in this Notice.

Purposes for processing Personal Data

The Company collects, processes, and otherwise uses your Personal Data for purposes (a) that are required by applicable law, regulations, collective agreements or other contracts, (b) to allow the Company to fulfil its business needs and legal obligations and (c) to maintain the employment relationship or other business relation with you. These purposes include but are not limited to:

• management of the employment and contractual relationship;
• workflow management, such as assigning, managing, and administering projects or training;
• travel and expense tracking and budgeting;
• compensation administration, including payroll, bonus, approval and processing; benefits monitoring, calculation, administration and planning; competitive pay analysis, and job grading;
• talent management; performance reviews, promotion, and career development activities; identifying future managers and leaders (succession planning); retirement planning, monitoring of training and development;
• personnel administration;
• enrolment with and administration of health and medical benefits, pension funds or retirement plans;
• administration of leave of absence, time off, sick leave or other types of employee leave as per applicable law and/or company policies;
• managing sickness, injury and/or disability requirements;
• managing health and safety risks;
• organisational development; preparation, management, and use of an internal business directory;
• external publicity and marketing purposes including press releases, externally available contact details and promotional purposes;
• employee discipline; internal company and/or external investigations into misconduct and/or performance concerns; audit requirements;
• exercise of our rights under local laws and compliance with applicable legal and regulatory requests and obligations (including investigations in relation to the same) and audit requirements;
• establish or defend legal claims and allegations;
• performing “know your customer” checks or responding to “know your customer” checks of third parties or similar due diligence requests;
• marketing funds or services of the Pantheon Group, for example providing biographical information and financial information on equity ownership in the Pantheon Group or investments in the funds managed or advised by the Pantheon Group (“Pantheon Funds”) to prospective clients or investors.

We will not use your Personal Data for the purposes of marketing to you unless you expressly consent to us doing so.

Disclosure of Personal Data

We will share your work contact details within the Pantheon Group for our legitimate business interests. Except in this regard, within the Pantheon Group, your Personal Data will be disclosed only to those individuals who need access to your Personal Data to perform their duties for the purposes listed in Section 4 above or where required or permitted by applicable law.

The Company may also disclose your Personal Data to other members of the Pantheon Group for pursuing the purposes listed in Section 4 above or where required by applicable law. Within the Pantheon Group, your Personal Data will be disclosed only to a limited number of restricted individuals within the information technology, human resources, legal, finance, regulatory and compliance, payroll, tax, accounting department as well as certain managers (i.e. only persons with assigned responsibility or managerial responsibility for the employee or groups of employees) to the extent any of these functions need access to your Personal Data in connection with their job responsibilities. Access will be provided on a need-to-know basis. Disclosure may take place also through specifically devoted human resources information systems and databases, employee directories or business applications. Access to the internal employee directory will be provided to all employees of the Pantheon Group limited to the information necessary to relevant work needs.

We may disclose personal data to third parties in connection with marketing and promotion of the Pantheon Group’s funds and services, e.g. bios in Information Memoranda, Due Diligence Questionnaires for Pantheon Funds, as well as basic financial information about equity ownership in Pantheon Group, investments in Pantheon Funds and carried interest.

The Company may also disclose your Personal Data to third parties, including those providing payroll services, information technology support or technical and organizational services in connection with human resources-related activities or legal, compliance audit or other advisors to the Company or another member of the Pantheon Group for the purposes referred to in this Notice. The Company will exercise appropriate due diligence in the selection of its third party service providers, and require that such providers maintain adequate technical and organizational security measures to safeguard your Personal Data, and to process your Personal Data only as instructed by the Company or a member of the Pantheon Group and for no other purposes.

The Company may also disclose your Personal Data to governmental authorities (including HMRC, the Benefits Agency and other agencies and authorities) as required or permitted by law; public and private social security and insurance agencies; credit reference agencies, debt collection agencies, consultants in connection with extraordinary business operations (e.g., mergers, acquisitions, and the like); to business partners, agents and customers (including to third parties performing “Know Your Customer”, due diligence checks or anti-money laundering checks on members of the Pantheon Group or its clients or investors); external consultants and professionals; associations, including trade unions and employee works councils; and courts. Your Personal Data will be disclosed to such third parties only as necessary in connection with the performance of contracts, the Company’s business activities and the purposes listed in Section 4 above, as permitted by employee consent or as otherwise authorized, required, or permitted by law.

We may also disclose information to an actual or prospective mortgage lender, an actual or prospective landlord, or to a former or prospective new employer, or a recruitment agency (with your express consent).

We may also disclose data to family, associates and representatives of Associates, for example in the case of a medical emergency, where you have previously provided consent for us to do so.

International transfer of Personal Data

Due to the multinational character of the Pantheon Group, some members of the Pantheon Group and other recipients listed in Section 5 above may be located in countries that do not provide a level of data protection equivalent to that set forth by the law in your home country. The Company will take appropriate steps to make sure that such recipients act in accordance with applicable law. To the extent that the Personal Data is transferred by a Company that is based in the European Economic Area or the United Kingdom to a recipient which is located in a territory outside the European Economic Area and the United Kingdom and which has not obtained a finding of adequate level of protection by the European Commission or by the UK under UK GDPR, as applicable, such Company will ensure that appropriate safeguards are in place to provide an adequate level of protection of your Personal Data, including appropriate technical and organizational security measures and through the implementation of appropriate contractual measures to secure such transfer, in compliance with applicable law, including the execution of standard contractual clauses in the form approved by the European Commission, or equivalent data transfer agreements, as required.

Legal basis for processing Personal Data

The Company’s employment obligations and contractual and legal obligations as well as its legitimate business interests under the Data Privacy Laws form the legal basis of the processing described in this Notice. If you are an employee of the Company, we will need to process your Personal Data for these purposes. Our legitimate interests or those of a third party include our requirements to use your Personal Data in litigation, investigations, regulatory or governmental enquiries or for other legal or regulatory purposes involving the Company and/or any affiliate of the Company and may also include the need to transfer your Personal Data to third countries without adequate data protection laws. In this event, we will take reasonable steps to protect your Personal Data as required by the Data Privacy Laws.

Data security

We maintain physical, technical, and organizational security measures to protect the Personal Data against accidental, unlawful, or unauthorized destruction, loss, alteration, disclosure, or access, whether it is processed in your local jurisdiction, the United States, or elsewhere. Our Information Security policy governs how we protect your Personal Data. Please reach out to the Chief Information Security Officer to view the policy.

Retention, Access and Accuracy of Personal Data

We intend to keep your Personal Data accurate and up-to-date. We also strive to retain your Personal Data no longer than is necessary to carry out the purposes listed in this Notice or than is required by law. The Company retains your Personal Data for a maximum of seven years following the end of your employment or other business relationship.

If changes need to be made to Personal Data, please notify the Human Resources Department (as identified below) in writing right away. Under applicable law, you have rights to: (i) check whether we hold Personal Data about you and to access such data (subject to applicable laws); (ii) request correction of Personal Data about you that is inaccurate; (iii) ascertain information related to the Company’s policies and practices in relation to Personal Data; (iv) request the erasure of your Personal Data; and (v) request the restriction of processing concerning you². In certain circumstances, you also may have the right to request restrictions or object for legitimate reasons to the processing of your Personal Data in accordance with the Data Privacy Laws. Further, you have the right to transfer your Personal Data to third parties pursuant to Article 20 of the GDPR.

Changes to the Notice

Should we materially change our Personal Data practices or this Notice, we will issue a revised Notice and/or take other steps to notify you of the changes in accordance with applicable laws.

Rights to raise concerns

You have the right to raise concerns to the Company, Data Protection Officer or to a supervisory authority about the Company’s processing of your Personal Data. If you wish to raise concerns with the Company, please contact a member of the Human Resource Team. Our UK supervisory authority is the Information Commissioner’s Office and our Irish supervisory authority is the Data Protection Commission.

In Ireland, under the Protected Disclosure (Amendment) Act 2022, job applicants have the right to report concerns about any wrongdoings they have encountered during their application. Follow this link if you would like to raise any concerns: ACA Compliance Alpha

Questions

If you have any questions about this Notice or wish to (i) access or review your Personal Data or learn more about who has access to your Personal Data, or (ii) make another type of request related to your Personal Data, please contact a member of the Human Resource Team. This Notice was issued on 22 August 2019, and subsequently updated on 31 December 2019, the 27 August 2020, 21 January 2021, 21 December 2022 and 30 January 2023.

¹Pantheon Group means Pantheon Holdings Limited, Pantheon Ventures Inc., Pantheon Capital (Asia) Limited, Pantheon Ventures (UK) LLP, Pantheon Ventures (HK) LLP, Pantheon Ventures (US) LP, Pantheon Ventures (Ireland) DAC, Pantheon Ventures (Singapore) Pte. Ltd. and each of their respective subsidiaries and subsidiary undertakings from time to time.

²For residents of California only, as required under the CCPA and CPRA, you may directly request, using the links below, limitations on how we may use and retain personal and sensitive information. Sensitive personal information is defined under the CCPA and CPRA as personal information that may reveal: an individual’s social security, driver’s license, state identification card, or passport number; account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account; precise geolocation; racial or ethnic origin, religious or philosophical beliefs, or union membership; contents of mail, email, and text messages unless the business is the intended recipient of the communication; genetic data.; or biometric information.

Do Not Sell or Share my Personal Information

Limit the Use of My Sensitive Personal Information

https://www.cigna.com/legal/compliance/machine-readable-files

This link leads to the machine readable files that are made available in response to the federal Transparency in Coverage Rule and includes negotiated service rates and out-of-network allowed amounts between health plans and healthcare providers. The machine-readable files are formatted to allow researchers, regulators, and application developers to more easily access and analyze data.

Please click here to download Pantheon’s Summary Complaints Reporting Policy for Luxembourg Funds.

This notice (“Notice”) is addressed to clients of the Pantheon Group¹ and any direct or indirect investor in any fund managed or advised by a member of the Pantheon Group (a “Pantheon Fund”).

Transaction Fees & Property Services Fees

Pantheon Group’s policy is not to retain transaction fees from managers or sponsors of third-party funds that are attributable to a portfolio investment by any given investment management or investment advisory client of the Pantheon Group (including any Pantheon Fund). Any such fees which are received are reimbursed to such client or offset against the fees otherwise due from such client to the Pantheon Group. However, fees associated with certain property services for real estate direct investments are permissible provided that any such fees will not exceed the rate that would be payable by the respective fund or such investment if such services were provided by unaffiliated third parties in the business of providing comparable services, unless otherwise consented to by the advisory committee of the fund.

Exceptionally, certain members of the Pantheon Group may act as placement agent for third party funds or companies and may receive compensation, directly or indirectly, from such entities, or an affiliate thereof, in connection with the purchase of interests in such entity. Such compensation may include broker or placement fees based on the percentage of capital raised for such entity or a share of management fee or carried interest payable from such entity. However, as described above, any such compensation that is attributable to the investment by any given investment management or investment advisory client of the Pantheon Group (including any Pantheon Fund) will be reimbursed to such client or otherwise offset against the fees due from such client.

Benefits

In connection with the provision of its services to clients of the Pantheon Group (including Pantheon Funds), members of the Pantheon Group may receive hospitality (including food and drink), and travel and accommodation costs and certain other non-monetary benefits provided by sponsors or managers of portfolio investments (or affiliates thereof), including for the purpose of facilitating attendance by members of the Pantheon Group on behalf of clients of the Pantheon Group (including Pantheon Funds) at periodic investor meetings for investors in portfolio funds or at meetings of advisory committees / advisory boards of portfolio funds, or during such meetings. The receipt of such hospitality and costs is incidental to attendance at, and participation in, such meetings which enhances the quality of the Pantheon Group’s services and does not impair the Pantheon Group’s ability to discharge its fiduciary duties. They are not dependent on or otherwise related to the level of assets invested by any individual underlying investor/client, and attendance at portfolio fund meetings is on behalf of all clients of the Pantheon Group (including Pantheon Funds) invested in such portfolio funds. Further details of such hospitality and costs received are available to clients of Pantheon Group and investors in Pantheon Funds upon request.
In this regard, the Pantheon Group is committed to conducting its business with integrity, paying due regard to the interests of clients (and investors in Pantheon Funds) and treating them fairly to ensure that business is based strictly on the value of the products and services the Pantheon Group offers, and not on the gifts or entertainment it gives or receives. The Pantheon Group has adopted a Gifts & Entertainment Policy which all members of staff are required to comply with.

Strategic Alliances

Certain real estate direct investment fund(s) are permitted to act in conjunction with third parties (including property owners, developers, joint venture partners, managers and other investors) for competitive or strategic reasons or for other reasons that Pantheon determines will be to the benefit of the fund(s). Such third parties are permitted to be offered the opportunity to venture or otherwise co-invest with the fund(s) (and Pantheon is permitted to do so without offering such opportunity to any Limited Partner), and Pantheon is permitted to receive and retain compensation (including a management fee, carried interest and/or other compensation (including Transaction Fees)) in conjunction with arranging and managing such arrangements.

April 2022

¹Pantheon Group means Pantheon Holdings Limited, Pantheon Ventures, Inc., Pantheon Capital (Asia) Limited, Pantheon Ventures (UK) LLP, Pantheon Ventures (US) LP, Pantheon Ventures (HK) LLP, Pantheon Ventures (Ireland) DAC and each of their respective subsidiaries and subsidiary undertakings, from time to time

We incorporate data from specific third parties in our publications and communications. Please review and understand the following important information provided by these third parties:

MSCI Inc.:
This document contains information (the “Information”) sourced from MSCI Inc., its affiliates or information providers (the “MSCI Parties”) and may have been used to calculate scores, ratings or other indicators. The Information is for internal use only, and may not be reproduced/redisseminated in any form, or used as a basis for or a component of any financial instruments or products or indices. The MSCI Parties do not warrant or guarantee the originality, accuracy and/or completeness of any data or Information herein and expressly disclaim all express or implied warranties, including of merchantability and fitness for a particular purpose. The Information is not intended to constitute investment advice or a recommendation to make (or refrain from making) any investment decision and may not be relied on as such, nor should it be taken as an indication or guarantee of any future performance, analysis, forecast or prediction. None of the MSCI Parties shall have any liability for any errors or omissions in connection with any data or Information herein, or any liability for any direct, indirect, special, punitive, consequential or any other damages (including lost profits) even if notified of the possibility of such damages.

London Stock Exchange: 
London Stock Exchange Group plc and its group undertakings (collectively, the “LSE Group”). © LSE Group 2024. FTSE Russell is a trading name of certain of the LSE Group companies. FTSE Russell® is a trade mark of the relevant LSE Group companies and is used by any other LSE Group company under license. All rights in the FTSE Russell indexes or data vest in the relevant LSE Group company which owns the index or the data. Neither LSE Group nor its licensors accept any liability for any errors or omissions in the indexes or data and no party may rely on any indexes or data contained in this communication. No further distribution of data from the LSE Group is permitted without the relevant LSE Group company’s express written consent. The LSE Group does not promote, sponsor or endorse the content of this communication.

S&P 500 Index:
The S&P 500 index, and Dow Jones US Total Market index (“Index(es)”) and associated data are a product of S&P Dow Jones Indices LLC, its affiliates and/or their licensors and has been licensed for use by Pantheon. © 2024 S&P Dow Jones Indices LLC, its affiliates and/or their licensors. All rights reserved. Redistribution or reproduction in whole or in part are prohibited without written permission of S&P Dow Jones Indices LLC. For more information on any of S&P Dow Jones Indices LLC’s indices please visit www.spdji.com. S&P® is a registered trademark of Standard & Poor’s Financial Services LLC (“SPFS”) and Dow Jones® is a registered trademark of Dow Jones Trademark Holdings LLC (“Dow Jones”). Neither S&P Dow Jones Indices LLC, SPFS, Dow Jones, their affiliates nor their licensors (“S&P DJI”) make any representation or warranty, express or implied, as to the ability of any index to accurately represent the asset class or market sector that it purports to represent and S&P DJI shall have no liability for any errors, omissions, or interruptions of any index or the data included therein.