ENGAGEMENT POLICY

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DECLARATION 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, regulating venture capital entities, other closed-end collective investment entities, and the management companies of other closed-end collective investment entities (“Law 22/2014”), Columbus Venture Partners, S.G.E.I.C., S.A.U. (“Columbus”) states that it has chosen not to develop an engagement policy, taking into account the following factors motivating this decision:

  • To date, the investment policy followed by the venture capital entities managed by Columbus, according to their management regulations, corporate bylaws, and informational prospectus, is primarily classified as venture capital. It focuses especially on making temporary investments in small and medium-sized enterprises that are in early stages of development and therefore are not listed on the primary market of stock exchanges or any other equivalent regulated market in the European Union or other OECD member countries.
  • Considering the portfolio of companies participated in by the entities managed by Columbus, none of these entities hold a stake in a company listed on a regulated market located in a Member State, with the exception of one portfolio company that, on one hand, is listed on a regulated market located in the United States, and on the other hand, the stake held by the vehicles managed by Columbus is very small and temporary in nature, with minimal impact on the decision-making level of such company.
  • As of the date of this declaration, Columbus does not foresee promoting and/or managing a venture capital entity with an investment policy in shares admitted to trading on a regulated market located or operating in a Member State.

Consequently, Columbus will not publish how the engagement policy has been applied nor the direction of its vote at the general meetings of listed companies in which the entities managed by Columbus hold shares, as this is not applicable.

Notwithstanding the foregoing, this declaration will be subject to review, update, or modification by Columbus based on the evolution and development of the investment policies followed by the managed venture capital entities.