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Disclaimer

Version 1.0

DocumentDisclaimer and important legal notice — boxwood.group
Version1.0
Effective date7 November 2026
Original languageEnglish (en-GB). Master version.
Applies toAll language versions of boxwood.group: /en/, /sr/, /de/, /pl/

1. Purpose and scope of this notice

1.1. This notice applies to the whole of the website published at boxwood.group (the “Website”), to every language version of it, and to every page, essay, news item, portfolio description, figure and image published on it (together, the “Information”).

1.2. The Website is operated by BOXWOOD CAPITAL DOO BEOGRAD, a company incorporated in the Republic of Serbia with registered address at Cara Lazara 5–7, 11000 Belgrade, registration number 21846244, tax identification number (PIB) 113327345 (“Boxwood”, “we”, “us”).

1.3. By accessing the Website you accept this notice. If you do not accept it, do not use the Website.

1.4. This notice is to be read together with the Terms of Use (/en/legal/terms/). Where the Terms of Use and this notice differ as to the nature or regulatory status of the Information, this notice prevails.

2. The Information is provided for general information only

2.1. The Information is published for general informational and corporate-communication purposes only. Its purpose is to describe who we are, what we do and how we think.

2.2. The Information is not directed at any particular person, does not take account of any person’s investment objectives, financial situation, knowledge, experience or needs, and is not suitable to be used as the basis of any decision.

2.3. No person should act, or refrain from acting, on the basis of anything published on the Website. Take independent professional advice before you act.

3. No offer and no solicitation

3.1. The Information does not constitute, and must not be construed as constituting:

  • an offer to sell, issue or dispose of any security, share, participation, unit, partnership interest, bond, loan participation, fund interest or any other financial instrument or investment (together, “Interests”);
  • an invitation, inducement or solicitation to make an offer to purchase, subscribe for or underwrite any Interests;
  • an invitation to invest, an invitation to participate in any investment, or an invitation to commit capital in any form;
  • a recommendation, advice or opinion that any person should acquire, hold or dispose of any Interests;
  • an offer of, or an invitation to enter into, any investment service or ancillary investment service;
  • a prospectus, an offering memorandum, an information memorandum, a private placement memorandum, a key information document, a securities information sheet, or any other offering or marketing document of any kind;
  • the basis of, or anything to be relied upon in connection with, any contract or commitment whatsoever.

3.2. No Interests are being offered on or through the Website. Boxwood is not raising capital from any person through the Website. Any transaction in which Boxwood participates is negotiated individually and bilaterally, is documented in signed transaction documents, and is not concluded, offered, promoted or pre-marketed through the Website.

3.3. No part of the Information may be treated as, or relied upon as, an assurance, promise or representation as to the future — including as to future performance, future returns, future distributions, future transactions, future ownership or the future composition of our portfolio.

4.1. Nothing on the Website constitutes investment advice, financial advice, portfolio management, investment research, a personal recommendation, an investment strategy recommendation, legal advice, accounting advice, regulatory advice or tax advice.

4.2. We do not provide any of those services to any person through the Website, and accessing the Website does not make you a client of Boxwood and does not create any advisory, fiduciary, agency or other relationship between you and us.

4.3. The essays published in the Perspectives section express the personal professional opinions of their named authors as at the date of publication. They are commentary. They are not investment research, they are not prepared in accordance with any legal requirement designed to promote the independence of investment research, and they are not subject to any prohibition on dealing ahead of the dissemination of investment research. Views expressed may change, and we are under no obligation to update them.

5. What Boxwood is, and what it is not

5.1. Boxwood is privately held by its founding partners. It invests only the partners’ own capital and holds and manages only its own assets.

5.2. Boxwood does not:

  • manage money, assets or capital for or on behalf of any third party;
  • operate, sponsor, advise, manage or market any fund, collective investment undertaking, investment company, alternative investment fund (AIF) or undertaking for collective investment in transferable securities (UCITS);
  • accept subscriptions, capital commitments, capital contributions or deposits from any person;
  • issue, offer or admit to trading any Interests in itself or in any vehicle managed by it;
  • provide any investment service or activity, including the reception and transmission of orders, execution of orders, dealing on own account for the purposes of providing a service to others, portfolio management, investment advice, underwriting, placing, or the operation of a trading facility;
  • act as a broker, dealer, placement agent, distributor, finder, introducer or intermediary for any person;
  • solicit, arrange or facilitate the participation of third parties in its investments through the Website.

5.3. Boxwood is not authorised, licensed, registered or supervised as an investment firm, a fund manager, an alternative investment fund manager, a credit institution or a financial services provider in any jurisdiction.

5.4. No pre-marketing. Nothing on the Website constitutes marketing, distribution, offering or pre-marketing of units or shares in an alternative investment fund within the meaning of Article 4(1)(aeb) and Article 30a of Directive 2011/61/EU (AIFMD), as amended by Directive (EU) 2019/1160, or of the national provisions implementing them. Boxwood is not an AIFM, manages no AIF, and does not provide any information about an investment strategy or an investment idea to any potential professional investor with a view to testing that investor’s interest in an AIF or a compartment that is not yet established or not yet notified for marketing.

5.5. Where the Website describes the possibility of investing alongside other investors, it describes a factual feature of past and possible future bilateral transactions negotiated individually. It is not an invitation to co-invest, is not addressed to any person, and creates no possibility of participating in any Boxwood investment by responding to the Website.

6. Information about portfolio companies

6.1. Descriptions of the companies in which Boxwood holds interests are published to illustrate the type of business we invest in and the way we work. They are provided for illustration only.

6.2. In particular, information about a portfolio company:

  • is not a recommendation or solicitation to buy, hold or sell any interest in that company or in any of its securities, and is not an offer of any such interest;
  • is not a representation that Boxwood currently holds, or will continue to hold, any interest in that company, or as to the size, form or terms of any interest held;
  • is not a complete list of Boxwood’s investments, and is not to be taken as representative of all investments made by Boxwood, including investments that performed less well or were unsuccessful;
  • describes the position as at the date of writing and may have ceased to be accurate;
  • is compiled in part from information provided by the company itself and from public sources, which we have not independently verified.

6.3. Statements describing what Boxwood contributed to a portfolio company are our own characterisation of our role. They are not an attribution of that company’s results to Boxwood, and they are not a statement of the returns achieved.

6.4. The names and marks of portfolio companies, of their customers and of third parties appear for identification purposes and do not imply any endorsement of Boxwood by them.

7. Past performance, forward-looking statements and third-party data

7.1. Past performance is not a reliable indicator of, and gives no guarantee as to, future results. The historical development of any business described on the Website, and any award, ranking or metric attributed to it, says nothing about its future performance or about the outcome of any investment.

7.2. The value of an investment can fall as well as rise. Investments of the kind described on the Website are illiquid, are exposed to concentrated market, technology, currency, country and counterparty risk, and can result in the loss of the entire amount invested.

7.3. The Website contains forward-looking statements — statements about intentions, expectations, plans, market development and the future. They are based on assumptions and on information available when they were made, they are subject to risks and uncertainties beyond our control, and actual outcomes may differ materially. We undertake no obligation to update them.

7.4. Market, sector and macroeconomic figures — including figures concerning the Serbian information and communications technology sector, employment, exports and gross domestic product — are taken from the third-party sources identified on the relevant page. They are reproduced in good faith, have not been independently verified by us, and may have been superseded. We give no warranty as to their accuracy or completeness.

8. Access from other jurisdictions

8.1. The Website is published from the Republic of Serbia and is addressed to a general audience. It is not directed at any person in any jurisdiction where the publication or availability of the Information would be contrary to law or regulation, or would subject Boxwood to any registration, licensing, notification or authorisation requirement in that jurisdiction.

8.2. Persons who access the Website do so on their own initiative and are responsible for observing the laws of the jurisdiction in which they are located, including any restriction on the receipt of information of this kind.

8.3. The Information may not be copied, forwarded, distributed or reproduced, in whole or in part, in any jurisdiction, or to any person, where to do so would breach any applicable law.

8.4. United States. The Information is not for release, publication or distribution, directly or indirectly, in or into the United States, and is not addressed to “U.S. persons” within the meaning of Regulation S under the United States Securities Act of 1933. No Interests have been or will be registered under that Act.

8.5. Republic of Serbia. The Information does not constitute a public offer of securities (javna ponuda) within the meaning of the Law on the Capital Market (Zakon o tržištu kapitala), no prospectus has been approved by or filed with the Securities Commission of the Republic of Serbia (Komisija za hartije od vrednosti), and Boxwood does not provide investment services (investicione usluge) within the meaning of that law.

9. Notice for readers in Germany

This section applies to you if you access the Website from Germany, are resident or established in Germany, or read the German-language version of the Website.

9.1. No public offer. The Information does not constitute a public offer of securities (öffentliches Angebot von Wertpapieren) within the meaning of Article 2(d) of Regulation (EU) 2017/1129 (the Prospectus Regulation) or of the German Securities Prospectus Act (Wertpapierprospektgesetz — WpPG). No prospectus has been drawn up, approved by the Federal Financial Supervisory Authority (Bundesanstalt für Finanzdienstleistungsaufsicht — BaFin) or published, and none is required, because no securities are being offered.

9.2. No offer of a non-securities investment. The Information does not constitute a public offer of an investment product (Vermögensanlage) within the meaning of section 1(2) of the German Capital Investment Act (Vermögensanlagengesetz — VermAnlG). No sales prospectus (Verkaufsprospekt) and no investment information sheet (Vermögensanlagen-Informationsblatt, VIB) has been prepared, filed or published, and none is required.

9.3. No fund, no marketing, no pre-marketing. Boxwood is not an alternative investment fund manager (AIF-Verwaltungsgesellschaft) within the meaning of the German Capital Investment Code (Kapitalanlagegesetzbuch — KAGB), it manages no investment fund (Investmentvermögen) within the meaning of section 1(1) KAGB, and it markets no units or shares in any investment fund. Nothing on the Website constitutes distribution (Vertrieb) under sections 293 et seq. KAGB, marketing to professional or semi-professional investors under sections 321, 323 or 330 KAGB, or pre-marketing (Pre-Marketing) within the meaning of section 306b KAGB. In particular, nothing on the Website is intended to test the interest of any potential professional or semi-professional investor in an investment fund or a compartment of an investment fund.

9.4. No investment services and no banking business. Boxwood provides no securities services (Wertpapierdienstleistungen) within the meaning of the German Securities Trading Act (Wertpapierhandelsgesetz — WpHG) and carries on no banking business (Bankgeschäfte) or financial services (Finanzdienstleistungen) within the meaning of section 1 of the German Banking Act (Kreditwesengesetz — KWG) — including, for the avoidance of doubt, no investment broking (Anlagevermittlung), no contract broking (Abschlussvermittlung), no placement business (Platzierungsgeschäft), no investment advice (Anlageberatung) and no financial portfolio management (Finanzportfolioverwaltung). Boxwood holds no BaFin authorisation and requires none.

9.5. No investment recommendation. The Information contains no investment recommendation or information recommending or suggesting an investment strategy within the meaning of Article 3(1)(34) and (35) of Regulation (EU) 596/2014 (Market Abuse Regulation) or of Delegated Regulation (EU) 2016/958.

9.6. No advertising of financial products. The Information is corporate communication about Boxwood’s own business. It is not advertising for financial instruments, capital investments or financial services within the meaning of section 12 VermAnlG, section 302 KAGB or Article 22 of Regulation (EU) 2017/1129, and it is not a marketing communication within the meaning of section 63(6) WpHG.

9.7. If, notwithstanding the above, you consider that any part of the Website reads as an offer, an invitation or a marketing communication addressed to you, please treat it as not so addressed and write to office@boxwood.group.

10. Notice for readers in Poland

This section applies to you if you access the Website from Poland, are resident or established in Poland, or read the Polish-language version of the Website.

10.1. No public offer. The Information does not constitute a public offer (oferta publiczna) of securities within the meaning of Article 2(d) of Regulation (EU) 2017/1129 or of the Act of 29 July 2005 on Public Offering and the Conditions for Introducing Financial Instruments to an Organised Trading System and on Public Companies (ustawa o ofercie publicznej i warunkach wprowadzania instrumentów finansowych do zorganizowanego systemu obrotu oraz o spółkach publicznych). No prospectus (prospekt), information memorandum (memorandum informacyjne) or information document (dokument informacyjny) has been prepared, approved by the Polish Financial Supervision Authority (Komisja Nadzoru Finansowego — KNF), notified to it or published, and none is required, because no financial instruments are being offered.

10.2. No advertising of an offer. The Information does not constitute an advertising communication (informacja reklamowa) relating to a public offer or to the admission of financial instruments to trading, and does not fall within Article 53 of the Act on Public Offering or Article 22 of Regulation (EU) 2017/1129.

10.3. No investment services. Boxwood does not provide brokerage activities (działalność maklerska) or any investment service within the meaning of the Act of 29 July 2005 on Trading in Financial Instruments (ustawa o obrocie instrumentami finansowymi), including the acceptance and transmission of orders, investment advice (doradztwo inwestycyjne), portfolio management (zarządzanie portfelami) and the offering of financial instruments (oferowanie instrumentów finansowych). Boxwood holds no KNF authorisation, is not entered in any KNF register, and requires no such authorisation or entry.

10.4. No alternative investment company and no marketing of one. Boxwood is not an alternative investment company (alternatywna spółka inwestycyjna — ASI), a manager of an alternative investment company (zarządzający ASI) or an investment fund within the meaning of the Act of 27 May 2004 on Investment Funds and the Management of Alternative Investment Funds (ustawa o funduszach inwestycyjnych i zarządzaniu alternatywnymi funduszami inwestycyjnymi). Nothing on the Website constitutes the offering, marketing, promotion or pre-marketing of rights of participation in an alternative investment fund or in an alternative investment company in the territory of the Republic of Poland.

10.5. Not addressed to Polish investors. The Polish-language version of the Website exists to make Boxwood’s own corporate information readable in Polish. It is not an invitation addressed to investors in Poland, it does not solicit capital in Poland, and it must not be read as directing any offer or investment opportunity at any person in Poland.

10.6. Boxwood is not supervised by the KNF and is not entered in the register of entities supervised by the KNF.

11. Enquiries sent to us

11.1. Writing to us at an address published on the Website does not create any contractual, advisory or confidential relationship and does not oblige us to reply, to evaluate what you send or to give reasons for any decision.

11.2. Material you send us unsolicited is not treated as confidential by reason of having been sent. See clause 5.2 of the Terms of Use. Do not send confidential or price-sensitive information to the addresses published on the Website.

11.3. Any indication on the Website as to how quickly we aim to respond is a statement of our working practice and not a contractual undertaking.

12. Limitation of liability

12.1. To the fullest extent permitted by applicable law, Boxwood, its shareholders, directors, officers, employees and advisers accept no liability of any kind for any loss or damage arising from access to, use of, or reliance on the Information, or from the unavailability of the Website.

12.2. Nothing in this notice excludes or limits any liability that may not lawfully be excluded or limited, including liability for intent, gross negligence, fraud or fraudulent misrepresentation, and including any liability arising under mandatory prospectus- or capital-markets-law provisions of any jurisdiction. Detailed provisions on liability are in clause 8 of the Terms of Use.

13. Changes to this notice

13.1. We may amend this notice at any time. The current version, with its version number and effective date, is the one published on this page.

13.2. Amendments take effect on publication. Please re-read this notice when you use the Website.

14. Language versions

14.1. This notice is drafted in English (en-GB). The English version is the original.

14.2. The English version is the only version of this notice; no translation of it is currently published. If a translation is published in future, it is intended to be substantively identical to the English version, not a summary and not a free rendering, and any divergence in meaning will be a defect to be corrected rather than resolved by treating one version as subordinate to another. The prevailing-language clause in the Terms of Use (clause 13.3) does not apply to this notice.

15. Contact

Questions about this notice, or about the regulatory status of anything published on the Website: office@boxwood.group · BOXWOOD CAPITAL DOO BEOGRAD, Cara Lazara 5–7, 11000 Belgrade, Republic of Serbia.