STATEMENT ON THE ENGAGEMENT POLICY OF COLUMBUS VENTURE PARTNERS, S.G.E.I.C., S.A.U.
In accordance with Article 67 bis of Law 22/2014 of November 12, which regulates venture capital entities, other closed-ended collective investment entities, and the management companies of such entities (“Law 22/2014”), Columbus Venture Partners, S.G.E.I.C., S.A.U. (“Columbus”) declares that it has opted not to develop an engagement policy, considering the following reasons:
As of the date of this statement, the investment policy followed by the venture capital entities managed by Columbus—based on their management regulations, articles of association, and prospectuses—is primarily classified as venture capital. It focuses on temporary investments in small and medium-sized enterprises in early stages of development, which are not listed on the primary market of any stock exchange or equivalent regulated market in the European Union or OECD countries.
Considering the portfolio of the companies invested in by the entities managed by Columbus, none of them holds a stake in a company listed on a regulated market located in a Member State, with the exception of one portfolio company that is listed on a regulated market in the United States. However, Columbus-managed vehicles hold only a small and temporary stake in that company, with minimal influence on its decision-making.
As of the date of this statement, Columbus does not plan to promote and/or manage a venture capital entity with an investment policy focused on shares admitted to trading on a regulated market located or operating within a Member State.
Consequently, Columbus will not publish information on the implementation of an engagement policy or the voting behavior at general shareholders’ meetings of listed companies in which the entities managed by Columbus hold shares, as this is not applicable.
Nevertheless, this statement will be subject to review, update, or modification by Columbus as the investment policies of its managed venture capital entities evolve.
