(Amended by a resolution of the BD of 24.08.2022)
In accordance with the requirements of Art. 75a, para. 5 of MFIA, the Board of Directors of Ever Financial AD / the company, the investment firm/ decided at a meeting held on 29.03.2021, not to be accepted and approved Engagement Policy of the investment intermediary according to art. 75a, para. 1 of MFIA due to the following reasons:
According to the adopted amendments to the European legal framework, new requirements have been introduced in the Bulgarian legislation regarding the exercise of certain shareholder rights arising from voting shares in connection with a general meeting of companies having their registered office in a Member State and which shares are admitted to trading on a regulated market located or operating in a Member State. In this regard is also the provision of Art. 75a, para. 1 of the MFIA requires investment firms providing a portfolio management service, which includes shares of companies established in a Member State which shares are admitted to trading on a regulated market, to adopt and publish an engagement policy and information on its implementation.
In this context, the investment firm should disclose the way in which participation in these public limited liability companies is integrated into an investment strategy in the management of clients’ portfolios. At the same time, the provision of Art. 75a, para. 5 of the law provides the possibility of not accepting the policy thus described and giving reasons for taking such a decision.
In this sense, it should be noted that the reasons for the above-mentioned changes are as follows:
In accordance with the above, when deciding not to adopt an Engagement Policy, the following facts and arguments were discussed and taken into account:
Based on the above, the Board of Directors of Ever Financial AD decided not to adopt an Engagement Policy at that moment, and in case of change of the relevant conditions, the decision will be reviewed.