Engagement Policy

Statement in relation to the engagement policy in accordance with the provisions of Article 67.bis of Law 22/2014, of November 12, regulating private capital entities, other closed-ended type collective investment entities and the management companies of closed-ended type collective investment entities (the “Law 22/2014”).

Pursuant to the provisions of 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 2017/828”) and its transposition in Spain by amending Law 22/2014, collective investment institution management companies (SGEICs) are required to publish on their website:

(i) (i) an engagement policy describing how they integrate engagement into their investment policy in case of investments on behalf of managed Private Equity Funds and Closed-end Investment Funds (“PEF” and “CEF”, respectively) managed in shares admitted to trading on a regulated market that is located or operates in a Member State; as well as a report on an annual basis on how it has implemented such engagement policy; or

(ii) (ii) publish a clear and reasoned explanation as to why it has not done so.

In this regard, Corpfin Capital Asesores, S.A., S.G.E.I.C. (“Corpfin”) understanding that the obligations set forth in Article 67 bis of Law 22/2014, are not applicable to it with regard to the development and publicity of an involvement policy, has chosen not to prepare an involvement policy and, therefore, not to prepare the annual report, for the reasons set forth below:

  1. Pursuant to Article 9 of Law 22/2014 and the respective management regulations of the PEF managed by Corpfin, the investment policy of the PEF managed by Corpfin is focused on taking temporary equity stakes in the capital of companies of a non-real estate and non-financial nature which, at the time of taking a stake, are not listed on the first market of stock exchanges or any other equivalent regulated market in the European Union or in the other member countries of the Organization for Economic Cooperation and Development.
  2. Consequently, as of the date of this statement, none of the PEF managed by Corpfin have holdings in companies whose shares are admitted to trading on a regulated market located or operating in a Member State of the European Union.
  3. The situation described in the second reason is not expected to change in the short or medium term.
  4. As of the date hereof, Corpfin has not entered into any asset management services agreements with insurance companies or pension plans and funds.

Notwithstanding the foregoing, Corpfin, in compliance with the provisions of Articles 16, 59.1d) and 61 of Law 22/2014, has approved a conflict of interest prevention and management policy applicable to all those investments that the Management Company makes on behalf of its managed entities, and which is duly published on the website of the Management Company in the “Responsible Management” section (

Furthermore, and in relation to the strategy for the exercise of voting rights referred to in Article 37 of Commission Delegated Regulation (EU) 231/2013 of 19 December 2012, Corpfin, in accordance with its investment criteria and the investment policies established for the entities it manages, implements suitable and effective strategies to determine the direction of voting in its investee companies, delimiting the scope of action of its representatives and establishing specific requirements that have been put in place with the objective of benefiting and favoring the profitability and efficiency of the investments of managed entities and, therefore, of the investors of the same.

In any case, this statement, and therefore Corpfin’s decision on the design and implementation of the engagement policy and its annual reports, is subject to review, update or modification due to changes in the applicable regulations or in the investment policies of the PEF under its management.

In Madrid, on 12 July 2023