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Legal Notice / Ethical Channel / Shareholder Engagement Policy


Portobello Capital Gestión, SGEIC, S.A. has established generally accepted technological security standards in order to protect the information provided by visitors from any improper use, loss or modification. Only authorized personnel have access to the personal and identification information offered through the site. Employees who have access to this sensitive information must keep it confidential. In the event of breach, the corresponding penalties will be applied to them. This policy is also applicable to any entity related to Portobello Capital Gestión, SGEIC, S.A. that has to receive such information from Portobello Capital Gestión, SGEIC, S.A. Notwithstanding the above, all visitors should be aware that our website contains links to other sites that are not controlled by this or other privacy policies.



  1. General information


This Legal Notice has been drawn up with regard to and in compliance with the provisions set out in the EU General Data Protection Regulation 2016/679, the Data Protection and Guarantee of Digital Rights Act 3/2018, of 5th December, and in Act 34/2002, of 11th June, on Information Society Service and E-Commerce.

This Legal Notice regulates the use and utilization of the Portal accessed through the Internet address (hereinafter “”), which Portobello Capital Gestión, SGEIC, S.A. with registered office at C/ Almagro 36, 2ª planta – Madrid 28010 Madrid, Spain and C.I.F. number A-86262375, registered in the Registro Mercantil de Madrid, torno 2 9. O 64, folio 80, sheet number M-523318, inscription 1ª, registered in the official registry of closed-end investment entities of the Comisión Nacional del Mercado de Valores with number 92 of its official registry makes available to Internet users.

The above-mentioned website has been designed to make known the information, activities and services offered by

The use of the Portal confers the status of user (hereinafter the User) and implies acceptance of all the conditions included in this Legal Notice, and the User should read this Legal Notice carefully every time he/she intends to use the Portal, as the conditions of use may undergo modifications.

Access to the Portal is unrestricted and free of charge except with regard to the cost of connection through the telecommunications network supplied by the access provider contracted by users.

The use of certain services offered to Users through the Portal may be subject to specific particular conditions (hereinafter the “Particular Conditions”) which, as the case may be, replace, complete and/or modify this Legal Notice. Accordingly, prior to using such services, Users must also read the corresponding Particular Conditions carefully.

In any case, it should be noted that the price for the services provided by is as indicated in the corresponding commercial offer and such services are not provided through the Portal.

The term of this agreement is limited to the utilization of the Portal and, consequently, the contract will terminate when Users log out from the Portal.


2. Use of the Portal


Users must make proper use of the Portal in accordance with the law and this Legal Notice, and shall be liable for any damages caused as a result of breach of the aforesaid obligation.

In the event that the User wishes to access the investors’ area of through the Portal, he/she must have registered and provided the data he/she is asked for, and have communicated a username and password, which he/she must keep and use diligently.

Furthermore, the information the User provides through the Portal form must be true. Accordingly, the User warrants the authenticity of all the data he/she communicates and undertakes to keep the information provided to perfectly updated so that it matches the User’s real situation at all times, and is solely liable for any false or inaccurate statements he/she makes and for any damages caused to or to third parties due to the information he/she provides.


III. Links


In the event that an Internet user adds a link from his/her website to the Site, the link will only link to the home page of the Portal, but may not reproduce it in any way, and in the event that the contents of the Portal can be viewed together with unrelated content, such unrelated content may not mislead or cause errors or confusion in Users as to the source of the Portal contents, nor constitute an act of unfair comparison or imitation or taking unfair advantage of the reputation of

The site from which the link is added will not make any false or inaccurate representation concerning, its partners, employees or clients, and will not state that it has the consent of to insert the link, or that has any relationship or collaboration with that site.

Except in cases permitted by law or expressly authorized by, whenever a direct link to the Portal is permitted, the use of any trademark or any other distinctive mark of in the site where the link is located is prohibited.

The site that establishes the link must comply with the law and must not contain or link to content that is unlawful or contrary to morals and custom.

For its part, the Portal includes technical linking devices that allow the User to access other Internet websites and portals,           where acts as provider of intermediation services in accordance with article 17 of Act 34/2002, of 11th July, on Information Society Service and E-Commerce, and therefore will only be responsible for the contents and services provided in the linked sites if it has had actual knowledge, in the manner established by the Information Society Services Act, of the unlawfulness and has failed to disable the link.

The existence of linked sites does not mean that there are any agreements with the managers or owners thereof, and does not accept liability for any damages caused by the unlawfulness, quality, outdatedness, lack of availability, error or lack of usefulness of the content of such sites, as it is unaware of them. In any case, if the User were to become aware that the linked sites lead to pages the contents or services of which are unlawful or contrary to morals, he/she must notify of this.

For these purposes, the e-mail address is provided. In this way, users should provide: name, address. Telephone number and e-mail address; specification of the alleged unlawful activity carried out on the Portal; facts or circumstances that reveal the unlawful nature of such activity;


  1. Intellectual Property reserves all rights on the trademarks, trade names or other distinctive marks, patents, other intellectual property, in relation to the content and design of this Internet Portal.

In particular, the contents appearing now or in the future on the Portal (text, photographs, images, icons, software, links, graphic design, source code, etc.) are the property of or of third parties that have expressly authorized to include them in the Portal. It will not be understood under any circumstances that grants the User any licence whatsoever or that it waives, transfers or assigns in full or in part its rights on such contents, or that it confers any right of transformation, exploitation, reproduction, distribution or public communication on the contents.

Likewise, the trademarks, trade names and other distinctive marks appearing in this Portal are the property of their respective owners. The User accepts that access to this Internet Service should not be understood as the tacit granting, by virtue of the doctrine of estoppel or any other mechanism, of any licence or right of use of any trademark, trade name or any other distinctive mark in this Portal without the prior written consent of or their respective owners.


  1. Liability is not bound to verify the veracity, accuracy and updating of the information provided through its website. does not accept liability for decisions made based on the information provided on the Portal, or for any damages caused to the User as a result of actions based solely on the information obtained on the Portal, as the contents of this site are of a general nature and do not constitute the provision of any type of professional services, and therefore the aforesaid information is insufficient for professional or business decision-making by the User.

Access to the Portal does not entail the obligation by to control the absence of viruses or any other harmful computer element, and it is up to the User to have adequate tools for the detection and disinfection of harmful computer programmes, and therefore does not accept liability for any damage caused to the computer equipment of Users or third parties during the provision of the Portal service. does not accept liability for any damage caused to the User caused by breakdowns or disconnections in the telecommunications networks that lead to the suspension, cancellation or interruption of the Portal service during the provision thereof or prior or subsequent to the provision of the service.


  1. Legislation


This Legal Notice is governed in each and every one of its aspects by Spanish law, and any controversy deriving from it will be resolved by the Courts of the city of Madrid.

In any case, it would be possible to establish that any litigious matters be resolved by Arbitration in Law:

“For any litigious matters arising in relation to the Portal, the parties agree to resolve them through Arbitration in Law in the framework of the Arbitration Court of Madrid of the Official Chamber of Commerce and Industry of Madrid, which is entrusted with administering the arbitration and designating the arbiters in accordance with its Rules and Bylaws, waiving any other venue that might correspond to them”.


Ethical Channel


Portobello proceeds to present its Internal Communication platform. Through this platform, you have the option to report, in privacy, any concerns about potential improper actions that could represent a criminal or administrative offence.


This medium is designed especially for current and former employees, suppliers, shareholders, managers, associates and board members.


In accordance with the Spanish Law 2/2023 of 20 February 2023, which regulates the protection of persons who report breaches of regulations and the fight against corruption, the Non-Compliance Reporting Channel is a transparent instrument for Portobello Professionals or third parties related to Portobello to report conduct that may imply the commission of any irregularity or any act contrary to the law or internal rules of conduct or to consult any doubts that may arise in their interpretation. Communications sent to the Compliance Channel will be analysed and managed by the person in charge of the Compliance Channel designated by Portobello in a strictly confidential manner.


If you prefer, you may choose to communicate through the External Channel managed by the “Entidad Independiente de Resguardo al Denunciante”, designated by the Spanish Government.


Please complete the required fields and, for a better service, we suggest you provide as specific data as possible in the following link:


We guarantee you the option to make your report anonymously. However, it is necessary to provide us with an email address in order to be able to respond to you. We reiterate that the information you submit will be handled in the strictest confidence, and will only be in the hands of the responsible for the Compliance Channel.


Shareholder Engagement Policy


It is not considered necessary to draw up a Shareholder Involvement Policy, in accordance with Article 67 bis of Law 22/2014, since the investees of the managed vehicles are not listed.