BLUE MOUNTAIN CAPITAL
Engagement
Policy.
Declaration pursuant to Article 67 bis of Law 22/2014.
Declaration regarding the Engagement Policy
In accordance with Article 67 bis of Law 22/2014, of November 12, which regulates venture capital entities, other closed-end collective investment entities, and management companies of closed-end collective investment entities («Law 22/2014»).
In accordance with Directive 2017/828/EU of the European Parliament and of the Council of May 17, 2017, amending Directive 2007/36/EC as regards the encouragement of long-term shareholder engagement (the «Directive 2017/828») and its transposition in Spain through the amendment of Law 22/2014, management companies of closed-end collective investment entities are required to publish on their website an engagement policy describing how they integrate engagement into their investment policy when investing on behalf of the managed ECR and EICC in shares admitted to trading on a regulated market located or operating in a Member State; as well as an annual report on how they have applied said engagement policy; or, alternatively, publish a clear and reasoned explanation of why they have not done so.
Blue Mountain Asesores, S.L.U. and its dependent entities (hereinafter, «Blue Mountain Capital«) understands that the obligations set out in Article 67 bis of Law 22/2014 do not apply to it with regard to the development and publication of an engagement policy and, therefore, has chosen not to prepare an engagement policy or prepare the annual report referred to in the regulation, for the reasons set out below:
- In accordance with Article 9 of Law 22/2014, Blue Mountain Capital’s investment policy focuses on taking temporary stakes in the capital of non-real estate and non-financial companies that, at the time of the investment, are not listed on the primary stock exchange market or any other equivalent regulated market in the European Union or other member countries of the Organization for Economic Cooperation and Development. Thus, none of the investments managed by Blue Mountain Capital holds stakes in companies whose shares are admitted to trading on a regulated market located or operating in a Member State of the European Union.
- The situation described is not expected to change in the short or medium term.
- Blue Mountain Capital does not provide asset management services to insurance companies or pension plans and funds.
This declaration is subject to review, update, or modification in light of the development of the investment policies of the vehicles managed at any given time.
Last updated: January 2026
Blue Mountain Asesores, S.L.U.
Paseo de la Castellana, 40, Floor 8
28046 Madrid, Spain
