Engagement policy
Statement regarding the Engagement Policy pursuant to Directive (EU) 2017/828 of the European Parliament and of the Council of 17 May 2017 amending Directive 2007/36/EC as regards the encouragement of long-term shareholder engagement (the “Directive”)
In accordance with the provisions of the Directive and its transposition into Spanish law through the amendment of Law 22/2014 of 12 November regulating venture capital entities, other closed-end collective investment entities and management companies of closed-end collective investment entities, specifically based on the wording of its new Article 67 bis, (*) SGEIC, S.A. must publish on its website an engagement policy describing how it integrates shareholder engagement into its investment policies in the case of investments, on behalf of the managed ECRs and EICCs, in shares admitted to trading on a regulated market that is located or operates in a Member State, or otherwise publish a clear and reasoned explanation as to why it has not done so.
(*) [SGEIC, S.A.] states that, in accordance with said regulation, it has chosen not to draw up an engagement policy or publish it on its website, because the investment policies of the ECRs/EICCs it manages mean that no investments will be made in shares of companies admitted to trading on a regulated market located in a Member State of the European Union, in accordance with the aforementioned Law 22/2014.
Venture capital entities mainly aim to take temporary equity stakes in the share capital of companies that are neither real estate nor financial in nature and that, at the time the stake is acquired, are not listed on the main stock exchange market or on any other equivalent regulated market of the European Union or of other member countries of the Organisation for Economic Co-operation and Development. It should be noted that there may be some special investment circumstance involving an entity that is listed on a regulated market, but such investment would be temporary. In any event, if, on a temporary basis, the ECR-EICC were to hold any investment in a listed company, such investments would not represent a relevant percentage of the shares or voting rights of those listed companies.
It should be noted that, as there is no obligation to implement an Engagement Policy, the annual report referred to in that article will not be issued. Nevertheless, the management company keeps its investors informed of the relevant aspects of engagement as partners or shareholders in the investee companies in which the ECR-EICC under management invest.
This statement, and therefore the decision taken by the management company regarding the design and application of the engagement policy and its annual reports, is subject to review, updating or modification due to regulatory developments or changes in the entities under its management.