Shareholder engagement policy statement

Pursuant to the provisions of Article 67.bis of Law 22/2014, of 12 November, regulating private equity entities, other closed-end collective investment entities and management companies of closed-end collective investment entities, and amending Law 35/2003, of 4 November, on Collective Investment Undertakings (the “Law 22/2014”), ZUBI CAPITAL ASSET MANAGEMENT, SGEIC, S.A.U. “Alias the Manager” must either publish on its website (i) an engagement policy describing how it integrates shareholder engagement into its investment policies in the case of investments by managed private equity entities in shares admitted to trading on a regulated market that is located or operates in a Member State, and an annual report on how such investment policy has been implemented; or publish (ii) a clear and reasoned explanation as to why it has not done so.

In relation to the above, the Gestora has chosen not to produce an involvement policy and therefore not to produce the annual report for the following reasons:

The Management Company does not invest in shares of companies admitted to trading on a stock exchange market or any other equivalent regulated market located in a Member State of the European Union or of the other member countries of the Organization for Economic Cooperation and Development (“OECD”), but rather, in accordance with Article 9 of Law 22/2014, focuses on making temporary early-stage investments in companies of a non-real estate or non-financial nature which, at the time of taking a stake, are not listed on the regulated market of stock exchanges or any other equivalent regulated market in the European Union or the rest of the OECD member countries.

Thus, as of this date, none of the private equity entities managed by the Management Company has holdings in companies whose shares are admitted to trading on a regulated market located or operating in a Member State of the European Union or the OECD.

Likewise, this situation is not expected to change in the short or medium term.
It is for this reason that the obligation to draw up an application policy and its corresponding publication on the website is not applicable to the Gestora.
Likewise, for the purposes of Article 67.ter of Law 22/2014, it is reported that, as of the date of this statement, the Gestora does not provide asset management services to insurance entities, plans or pension funds.

This declaration shall be subject to review, update or modification by the Gestora if there were causes that so required according to the private equity entities managed at any time or due to any applicable regulatory changes.

In Madrid on July 18, 2024
ZUBI CAPITAL ASSET MANAGEMENT, SGEIC, S.A.U.