Engagement Policy

In accordance with the provisions of Article 67.bis of Law 22/2014, of 12 November, regulating venture capital entities, other closed-ended collective investment undertakings, and the management companies of closed-ended collective investment undertakings (“Law 22/2014”), and Law 35/2003, of 4 November, on Collective Investment Undertakings, Teset Capital, S.G.E.I.C., S.A. (“Teset Capital”) is required to publish on its website an engagement policy describing how it incorporates shareholder engagement in its investment strategy in the event of investments on behalf of the venture capital entities (ECRs) and closed-ended collective investment undertakings (EICCs) it manages, in shares admitted to trading on a regulated market situated or operating in a Member State. Teset Capital must also publish an annual report detailing how such engagement policy has been implemented; or alternatively, publish a clear and reasoned explanation of why it has not done so.

Teset Capital has opted not to develop an engagement policy and therefore not to produce the related annual report, for the following reasons:

1. In accordance with Law 22/2014 and with the respective management regulations of the ECRs managed by Teset Capital, the investment policy of the ECRs managed by Teset Capital consists of acquiring temporary equity holdings in companies of a non-real estate and non-financial nature, which, at the time of investment, are not listed on the main stock exchange or any other equivalent regulated market in the European Union or in other member countries of the Organisation for Economic Co-operation and Development (OECD).
2. As of the date of this statement, none of the ECRs managed by Teset Capital hold shares in companies whose equity securities are admitted to trading on a regulated market situated or operating in an EU Member State, and there are no plans for this situation to change in the short term.
3. As of the date of this statement, Teset Capital has not entered into any asset management service agreements with insurance companies or pension plans and funds.
4. This statement, and consequently Teset Capital’s position regarding the application of an engagement policy, is subject to review, update, or modification.