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 (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 in the United Kingdom (FCA Reference Number 520240). Pantheon Ventures (UK) LLP is obliged to disclose certain information required under Pillar 3. This information and Pantheon’s Remuneration Policy are accessed by clicking on the following link:
Click here to access Pantheon’s Pillar 3 disclosure and Remuneration Policy as at 31st December 2021.
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 Sobo Works, Windmill Lane, Sir John Rogerson’s Quay, Dublin 2, D02 K156 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 2021.
Pantheon Ventures (HK) LLP is regulated by the Securities and Futures Commission (SFC) in Hong Kong (CE Number AVD736) for Advising in Securities.
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 focussed 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 (available here www.pantheon.com/corporate-responsibility) 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 recognise 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.
Privacy Policy: Your privacy is important to us and Pantheon has a firm commitment to privacy. Our Website Privacy Policy is available here. By accessing or using this site, you are agreeing to the terms set forth in the Website Privacy Policy. In addition, if you are an existing or prospective client of Pantheon or an existing or prospective, investor in any fund managed or advised by Pantheon (a “Pantheon Fund”), or a member, partner, shareholder, beneficial owner, officer, director, employee or other representative of any of the foregoing, please click here to read our Client Privacy Notice. Pantheon may also record calls as required under applicable laws for the purposes of establishing the existence of facts relevant to the business and for record keeping purposes in relation to instructions given or received or for any other lawful reason.
Trade marks. All service logos and slogans, company and product names, whether or not appearing in large print or with the trade mark symbol, are trade marks of Pantheon, its affiliates, related companies or its licensors or joint venture partners, unless otherwise noted. The use or misuse of these trade marks, or any other materials, except as permitted herein, is expressly prohibited and may be in violation of copyright law, trademark law, the law of slander and libel, the law of privacy and publicity, and communications regulations and statutes, trade marks represented on this website is expressly prohibited.
Copyright. The entire contents of this website are subject to copyright protection: Copyright © 2016 Pantheon. All rights reserved. You may not copy, display, download, distribute, modify, reproduce, republish or retransmit any information, text or documents contained in this website or any portion thereof in any electronic medium or in hard copy, or create any derivative work based on such images, text or documents, without the express written consent of Pantheon.
Other Intellectual Property Rights. Nothing contained herein shall be construed as conferring by implication, estoppel or otherwise any licence or right under any patent or trade mark other intellectual property right of Pantheon or any third party. Unauthorised use of content from this website may be in violation of patent law, the law of defamation, the law of privacy and publicity, or communications regulations and statutes.
Risks: In general, alternative investments such as private equity, infrastructure and real assets investments involve a high degree of risk, including potential loss of principal invested. These investments can be highly illiquid, charge higher fees than other investments, and typically do not grow at an even rate of return and may decline in value. These investments are not subject to the same regulatory requirements as registered investment products. In addition, past performance is not necessarily indicative of future results. Future performance is not guaranteed, and loss of principal may occur.
Important Information: Disclaimers, Limitation of Liability and Indemnification
Disclaimer of Liability. Save to the extent required by applicable law and regulatory requirements, Pantheon hereby disclaims all warranties and representations of any kind with regard to this website, including any implied warranties of merchantability, non-infringement of third-party rights, freedom from viruses or other harmful code, or fitness for a particular purpose.
This website and the information contained herein are provided “as is.” Pantheon does not warrant the accuracy, adequacy or completeness of the information and material contained on this website and expressly disclaims liability for errors or omissions in such information and materials. Pantheon does not make any commitment to update material or information on this website.
Limitation of Liability: Pantheon is not liable for any consequential, incidental, special, punitive or exemplary damages arising out of any use of or inability to use this website or any portion thereof, regardless of whether Pantheon has been advised of the likelihood of such damages occurring and regardless of the form of action, whether in contract, warranty, tort (including negligence), strict liability, or otherwise.
Indemnification: By accessing and/or using this website, you agree to indemnify, defend and hold Pantheon and its respective officers, directors, partners, employees, members, agents, information providers, affiliates, licensors and licensees (collectively, the “Indemnified Parties”) harmless from and against any and all liability and costs, including without limitation reasonable attorneys fees and expenses, incurred by the Indemnified Parties in connection with any claim arising out of or breach by you of these Terms and Conditions or the representations, warranties and covenants deemed made by you hereunder. You agree to cooperate as fully as reasonably required in the defense of any claim. Pantheon reserves the right, at its own expense, to assume the exclusive defense and control of any matter otherwise subject to indemnification by you. You shall not enter into any settlement agreement which affects the rights of any of the Indemnified Parties or requires the taking of any action by any of them, without Pantheon’s prior written approval.
1Pantheon Group refers to 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, including any successor or assign of any of the foregoing entities for so long as such successor or assign is directly or indirectly a subsidiary or subsidiary undertaking of a holding company or parent undertaking of any of the foregoing entities or is controlled by any person or persons which control(s) any of the foregoing entities. Its principal operating entities are based in the US (San Francisco and New York), UK (London), Hong Kong, Ireland, Guernsey, Japan and S. Korea. Pantheon Ventures Inc. and Pantheon Ventures (US) LP are, inter alia, registered as investment advisors with the U.S. Securities and Exchange Commission (“SEC”). Pantheon Securities, LLC is an SEC registered Broker Dealer and FINRA member located in the U.S. Pantheon Ventures (UK) LLP is authorised and regulated by the Financial Conduct Authority (FCA) in the United Kingdom. Pantheon Ventures (HK) LLP is regulated by the Securities and Futures Commission in Hong Kong (SFC). 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) Ltd and a number of other Pantheon entities incorporated in Guernsey are regulated by the Guernsey Financial Services Commission (GFSC). Pantheon Ventures (Ireland) DAC is authorised and regulated by the Central Bank of Ireland (CBI). The registrations and memberships described above in no way imply that the SEC, FINRA, SIPC, FCA, GFSC, CBI, the SFC or the Type II Financial Instruments Firms Association of Japan or the Japan Investment Advisers Association have endorsed any of the referenced entities, their products or services, or this material.
