Documentation

The purpose of the Advisory Agreement is the provision by the Entity to the Client of a non-independent investment advisory service. Such advice shall consist of issuing personalised recommendations to the Client regarding one or more transactions related to financial products. Likewise, as described in this Agreement, the advisory service includes a periodic, at least annual, assessment of the suitability of the advised portfolio by the Entity’s staff.

The advisory service shall be governed by the provisions set out in this Agreement and, for all matters not expressly regulated herein, by the provisions of the Framework Agreement and its annexed documents.

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The Conflicts of Interest Policy includes information on the appropriate measures adopted to detect, prevent or manage any conflicts of interest that may arise in the course of providing any service or activity.

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The Incentives Policy includes information on compliance with the requirements for the admissibility of such incentives, their monitoring and record-keeping, as well as the information that must be provided to clients receiving investment services.

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The Remuneration Policy includes information on the most significant and relevant criteria regarding staff remuneration, which, given Crescenta’s characteristics, are deemed proportionate and appropriate to its size and to the services and activities carried out by the company.

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In accordance with Article 67.bis of Law 22/2014 of 12 November, regulating venture capital entities, other closed-ended collective investment entities, and the management companies of closed-ended collective investment entities (“Law 22/2014”), and with Article 47 ter of Law 35/2003 of 4 November on Collective Investment Schemes, Crescenta Investments, S.G.I.I.C., S.A. (“Crescenta”), is required to publish on its website an engagement policy describing how it integrates shareholder engagement in its investment policy in cases where the managed VCEs and CISs invest in shares admitted to trading on a regulated market located or operating within a Member State, as well as to publish an annual report on how such engagement policy has been implemented; or alternatively, to provide a clear and reasoned explanation as to why it has not done so.

Crescenta has chosen not to prepare an engagement policy and therefore not to issue the corresponding annual report, for the following reasons:

1. In accordance with Law 22/2014 and the respective management regulations of the VCEs managed by Crescenta, the investment policy of such VCEs consists of taking temporary equity stakes in non-real-estate and non-financial companies which, at the time of investment, are not listed on the main stock market or any other equivalent regulated market within 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 VCEs managed by Crescenta hold equity interests in companies whose shares are admitted to trading on a regulated market located or operating within an EU Member State, nor is this situation expected to change in the short terms.
3. As of the date of this statement, Crescenta has not entered into any asset management service agreements with clients.
4. This statement, and therefore Crescenta’s decision regarding the application of the engagement policy, is subject to review, updating, or modification.