Editorial demonstration · 12 September 2026
SATIRICAL / CARICATURE REPRESENTATION — NOT A REAL ADVERTISEMENT
An imaginary issuer demonstrates what it would mean to explain the history, relationships, financing, risks and corrections. Real questions about RICPE and Orion are separated from the fictional voice.
No real issuer, securities, money request or regulatory approval.
Illustrative disclosure supplement · 13 September 2026. This is Por Derecho's evidence-based counterfactual disclosure exercise. It is not an issuer statement, an offer, a CNMV-approved prospectus or an authorised shelf/base prospectus. It does not impersonate Orion or Portfolio, fabricate an admission by any person, or treat allegations as established misconduct.
Historical role — documented. BORME identifies Martin Paul Graham as a director of Portfolio's operator in a registration dated 11 October 2022 and records cessation on 30 July 2025. The December 2024 complaint therefore arose during the registered tenure of a specifically identified director, not only during that of the current board.
Individual notice — independently documented send, separately reported acknowledgement. The native 10 December 2024 email escalated the Orion/CNMV complaint to Graham. Gil's 11 December WhatsApp transcription attributes to him awareness of the issues and forwarding of the compliance response. The latter remains a supplied transcription; it is not silently promoted to a native authenticated chat or a confession of misconduct.
Institutional action — documented acknowledgement and later reported review. The separate native 12 December compliance response confirms receipt and logging and describes review and authority contact it intended to undertake. The 17 January 2025 native follow-up again included Graham. Portfolio's 11 September 2026 response reports incorporation, internal review and transmission to CNMV. An accurate account includes that response.
Open decision — to be supplied. The reviewed record does not supply a complete issue-by-issue decision, the board/committee distribution record, evidence of the December contact with CNMV, a conflict/recusal schedule, a record of handover on cessation, or the reasoned decision on a public correction by the operator. These should be requested, examined and dated. Their absence from this review is not proof that no such record exists.
A document published in November 2024 could not disclose a complaint first made in December. The relevant exercise is therefore a dated post-notice supplement and subsequent disclosure history, alongside a separate test of facts known or reasonably required before the initial memorandum. Later notice cannot manufacture earlier knowledge.
The issuer and operator have distinct responsibilities. A candid supplement would explain any established material effect of the complaint history on the issuer's disclosures, and identify the operator's own findings or measures accurately. It would neither suggest that admission validated the contested history nor present an unresolved allegation against a director as an adjudicated issuer liability.
The exact-name UK business-record candidate, whose link to the Spanish director still requires confirmation, is relevant to asking about actual decisions, audiences and accountable people. It does not automatically establish UK control, UK financial promotion, FCA remit or a damages duty owed to every website reader. Corrections should reach the audiences that received any materially defective account, using the established legal and factual basis for each channel.
Notice chronology and sources · Board letter and requested remedies · International nexus review
SATIRICAL / CARICATURE REPRESENTATION — NOT A REAL ADVERTISEMENT
12 September 2026 · Editorial publication by Por Derecho / Gil Marer
Imaginary issuer: The Glass Perimeter, a fictional literary entity with no legal existence, assets, real directors or issued securities.
No money is offered or requested. There are no shares to subscribe for, orders to place, price, ISIN, admission, approved prospectus, CNMV approval or Portfolio Stock Exchange authorisation. This publication does not come from those institutions, Orion or RICPE. The character's voice is invented. References to real events appear separately, with their evidential limits.
Aviso en español: Representación satírica y caricaturesca. El emisor imaginario no existe. No hay oferta, suscripción, valores, aprobación regulatoria ni admisión a un mercado. La voz ficticia no es una cita ni admisión de una persona o entidad real. La comparación distingue información documentada, alegaciones y cuestiones abiertas.
| Item | Statement |
|---|---|
| Issuer | A literary character. |
| Capital sought | Zero. |
| Instruments offered | None. |
| Funds accepted | None; there is no payment channel. |
| Promised return | None. |
| Purpose | Criticism and a demonstration of documentary transparency. |
| Audience for the criticism | CNMV, Portfolio and people assessing investment information and its effects on others. |
| Status | Public editorial demonstration; not submitted for registration, approval or admission. |
Dear reader,
At The Glass Perimeter, we have adopted a potentially uncomfortable policy: the history does not expire when the cover changes.
If our presentation says we understand the market, we will identify what we also understand about the case file. If someone is an adviser in one year and a manager in another, we will give both dates. If several office holders sit at different tables, we will show the tables and identify who received which document. The word “independent” will be accompanied by an explanation of the engagement and the conflicts examined.
Someone suggested placing the unknowns in a section called “other matters”. We have decided to number them.
We will not turn registration into a guarantee of good conduct. We will not turn a complaint into a conviction. If a court found for us on a question, we will explain which question. If it left another unresolved, we will say so. Our collection of decisions will include those that spoil the narrative.
Why spend so many pages on relationships, old documents, loans, works and claims? Because a relationship that does not establish liability may still establish the question a reasonable reader needs to ask.
And because the case file does not disappear when we enter the investor room.
Yours sincerely,
The corporate history will not be in small print. We will identify the entity that contracts, receives payment, lends, owns, manages and promotes. A shared surname will not prove guilt. A shared abbreviation will not justify confusing companies.
Knowledge will have a date. We will distinguish professional work, documents received, explicit warnings and later decisions. “Worked at a firm” will not mean “knew every file”. “Not my contractual client” will not, by itself, answer “did you receive this document?”.
Financing will have a traceable path. We will show commitment, drawdown, payment, asset, security, beneficiary and eligible cost. Mortgage coverage will not be presented as cash received. If an investment combines tax advantages and assistance, we will explain each regime and cost. We will neither invent duplication nor dismiss it without checking.
Property will have a history. An initial sale, refusal of validation, later decision, deed and mortgage will occupy separate rows. The latest date will not erase the earlier ones. A favourable decision will not magically resolve questions it did not decide.
Claims will have an owner. If recovery is sought for an insolvency estate, we will not book it as a shareholder's unrestricted cash. A settlement without admission will be described as such. The same recoverable loss will not be counted twice.
Corrections will have an audience. If our account reached investors, lenders, authorities or others through an identifiable document or conversation, we will examine how to communicate the relevant correction. “Update PDF” will not be our only communication plan.
| Risk a transparent issuer should assess | Information this character would require before using reassuring words |
|---|---|
| Disputed Community authority or certificates | Original minutes, notices, representation, debt, vote, signature, specific use and the decision relying on it. |
| Continuity between an earlier asset and a later platform | Shared people and entities, actual contracts and flows; evidence, or absence of evidence, of value transfer. |
| Related manager, builder, promoter, lender or shareholder | Ownership at each level, engagements, prices, fees, abstentions, independent review and economic consequences. |
| Advisers with earlier and later roles | Dates, clients, confidentiality, conflicts, consents, barriers, custodians and actual access. |
| Lender with an investment or governance access | Precise rights, attendees, information received, credit decision, conflicts and monitoring. |
| Title or security with disputed history | Complete sequence, scope of each decision and other persons' rights left unresolved. |
| Works with several funding sources | Contracts, certificates, invoices and payments linked to loans, equity, RIC and identified assistance. |
| Pending litigation and potential recovery | Standing, defences, beneficiary, disputed amount, timetable, scenarios, costs and no double counting. |
| Impression of institutional endorsement | What was checked, by whom and to what extent; what admission or registration does not mean. |
| Complaint received after publication | Date, file, review scope, findings, response, correction and reasons for not acting. |
The fictional character's voice ends here. The following is a factual and editorial comparison of real documents and questions, not an invented confession attributed to their authors.
This publication does not assert that these documents omit every relationship or that all their statements are false. Orion discloses relevant relationships, transactions and risks; its 2025 audit has an unmodified opinion. The question is which further information or correction becomes material in light of specific facts, knowledge and dates. [S1–S2]
| Real subject | Starting point of the review | Further transparency or determination requested |
|---|---|---|
| Versions | Orion: initial document of 7 November 2024, update of 30 June 2026 and later notices. RICPE: historical copy located dated 4 June 2020. | Authenticate the RICPE 2024 edition referred to by the author of this criticism; do not invent its pages. Publish a version, change and dated-knowledge matrix. |
| Management and ownership | Orion identifies AGM Canary Asset Management and RICPE/Acosta Matos relationships. Pamalexsha's interest in AGM and ownership of Pamalexsha are different levels. | Explain control, indirect interests, powers, remuneration, conflicts and decisions. A&G and AGM are not interchangeable. |
| Professionals | Publications address PwC/RICPE careers, San Telmo/RSM integration and Cuyás/Grant Thornton connections. | Distinguish past and present, employment and engagement, Javier and Borja, local firm and network. The alleged direct Guerra–Borja partnership remains unproved. |
| PwC and the insolvency administrator in 2016 | Reviewed correspondence supports project work, client instructions concerning criminal proceedings and a general PwC–administrator telephone contact. | Verify separately the oral statement about the need for criminal action reported by Gil Marer; do not present words absent from the recovered email as proved by that email. |
| Recorded Community meeting in 2016 | The controlled date is 10 June. Derivatives and two audio files are located; technical and alignment limits remain. | Identify the proposition, speaker, context and subsequent conduct. Preserve contrary explanations; do not place the administrator or the Cogolludos at a meeting where their attendance is unestablished. |
| Portfolio audit | CNMV identifies Grant Thornton for 2024 and 2025. | Examine entity, team, other services, independence and actual knowledge. The engagement does not itself establish knowledge of Sun Park or validation of its titles. [S3] |
| Cajasiete | Orion shareholding and attendance with a voice but no vote are described in dated documents; 2023 Sun Park mortgage charges appear in the controlled documentary register. | Separate shareholder, lender and information access. Identify all relevant transactions, engagements and responses to notice; do not presume financing of the original 2018 purchase. |
| Commercial premises and later title | The 2018 transaction, 2019 refusal of validation, 2021 procedure/decisions, later title and financing. | Reconcile restitution, price, possession, accounting and individual properties. Preserve favourable later decisions; do not infer universal invalidity. |
| OB REM and building works | A legal link between properties and physical works are different matters. | Connect them through documents, costs, payments and funding without confusing the terms. |
| RICPE–Orion financing | The update reports a loan dated 30 December 2024, €6,385,844 drawn by end-2025 and an €8.5 million limit. | Contract, amendments, actual use, security, conversion, approvals and valuation. These are dated documentary figures, not a new cash audit. [S1] |
| Related construction | CAM billing of €7,126,468.39 in 2025 is reported. | Engagement, prices, certificates, payments, conflicts and independent comparison. A related-party connection alone does not establish abuse. [S1] |
| Capital increase and numerical accuracy | The 23 July notice reports 1,865,672 shares subscribed and paid at €1.34; the update contains inconsistent first-tranche figures. | Reconcile the figure, identify later deed/registration/admission and publish the relevant correction. Subscription is not admission to trading. [S1] |
| CaixaBank Valencia | ORD 1859/2023-9; controlled hearing date 28 January 2027. Provisional amount €1,124,445.84; standing and merits disputed. | Explain estate interest, beneficiary, settlement or judgment, releases, costs and actual effect on loss. No outcome automatically returns the hotel or determines Portfolio's liability. [S2] |
| Alleged Community capture/falsification | Gil Marer attributes creation or use of false debt, authority and documents to particular actors, with insolvency, administrative and investment consequences. | Investigate each document: author, false content alleged, recipient, notice, use, decision, harm and contrary evidence. Alleged economic continuity neither merges legal persons nor proves collective guilt. |
| Institutional response | On 11 September Portfolio confirmed incorporation, review and transmission of content to CNMV. | Acknowledge the development; obtain the substantive decision and communicable reference. Do not say Portfolio never replied or CNMV already accepted the allegations. [S2] |
In this criticism, “not located” means the search did not recover the document. It does not mean the document does not exist. No blank cell will be filled with a favourable or adverse conclusion for narrative convenience.
| Unknown | Evidence needed | Status in this edition |
|---|---|---|
| Exact PwC–administrator words about criminality | Note, audio, identified statement or formal response with date, participants and context. | Allegation awaiting verification. |
| Direct Guerra–Borja partnership | Primary source identifying the entity, dates and legal capacity. | Not established. |
| All Cajasiete–professional-firm engagements | Complete schedule by entity, matter, period and responsible person. | Not obtained. |
| Sun Park→Orion value flow | Identifiable account, contract, payment, loan, guarantee or transfer. | Not established by this review. |
| Exact RICPE 2024 edition | Complete copy and provenance/version record. | Not located. |
| Portfolio governance/control connection with the UK | Residence/capacity, ownership structure and actual activity. | Not established in the official records reviewed. |
| Final Portfolio review outcome | Competent decision, scope, reasons and measures. | Not obtained. |
This is an editorial model, not a notice issued or authorised by Portfolio:
Each corrected item, its earlier version and correction date are identified. The source prompting the change, its significance and the scope of verification are explained. Open questions, responses from the people concerned and earlier documents are retained. The issuer's measures are distinguished from those taken by the market operator within its powers.
The operator's own communication should express its own findings and decisions. Section 5.2.7(b) of Portfolio's Rulebook provides for a non-compliance communication within the relevant procedure. Its application requires established facts and a competent decision; this edition does not announce that such a decision exists. [S4]
Possible measures are not interchangeable: correcting an issuance document, restating accounts, informing recipients, changing governance/conflict handling, imposing market measures, recognising damages and recovering property require different grounds and decisions.
These questions seek an explanation of real criteria and actions. They do not seek approval, registration or admission of the imaginary issuer.
Here, tashkif madaf is a metaphor for a transparency file prepared and maintained in reserve. This text does not purport to meet the conditions of a European, British or Israeli base/shelf prospectus, or to obtain approval for a nonexistent entity.
Article 8 of the EU Prospectus Regulation governs base prospectuses for non-equity securities under its conditions. Orion's MTF admission/issuance document and RICPE's documentary regime require their own classifications. Prospectus approval is not an investment recommendation or guarantee. The UK offers/admission framework changed on 19 January 2026; no UK passport, authorisation or pre-approval is assumed. [S5–S6]
A future real issuer would require incorporation, responsible persons, accounts, assets, risks, offer structure and an actual regulatory assessment. This piece cannot be made available as a subscribable instrument. It remains criticism and a disclosure example, with visible sources, versions and corrections.
End of the satirical representation. This is not a communication from CNMV, Portfolio, Orion or RICPE. It cannot be used to raise funds.
To report an error or provide contrary evidence, identify the statement, source and proposed correction through Por Derecho’s contact route. Responses and corrections will be retained with their dates. This is an editorial publication, not an act of CNMV, Portfolio, Orion or RICPE. Por Derecho.
SATIRICAL / CARICATURE REPRESENTATION — NOT A REAL ADVERTISEMENT. Independent Por Derecho editorial reconstruction. No investment offer, real issuer admission or regulatory approval.
The promoter narrative described acquired properties, own funding and freedom from mortgages/charges. The presentation also described extensive professional controls.
A promoter statement, not an independent title finding.
54 CAM units · 190 LPB estate units · 18 third-party units. No Sun Park letter of intent signed; full due diligence had not started because the acquisition prerequisite remained unsatisfied.
262 registered units; a different denominator from the marketed apartment count. All 262 remain within the same Owners’ Community by title; this bar depicts dated ownership, not separate communities.
A San Telmo partner acknowledged that the firm had introduced several clients into the investment being discussed. The preserved context connects the investment perimeter to Acosta Matos/Sun Park.
Exact subscriptions, project allocations, fees and conflict safeguards remain to be established.
The preserved 08:08–08:12 passage includes “metimos unos cuantos clientes”. This acknowledges firm introductions; it does not say that San Telmo invested its own money or identify the destination of every subscription.
RICPE — shared investment platform; the two branches below are separate
Controlled 2023 reconciliation: €6,573,703.10. Component allocation remains open. RIC tax treatment, participating finance, 2023 Cajasiete mortgage charges and regional/FEDER records require separate tracing.
Issuer-reported RICPE loan: 30 December 2024; €6,385,844 drawn by end-2025; €8.5m ceiling. Issuer-reported CAM construction billing in 2025: €7,126,468.39. These are dated disclosures, not a new cash audit.
OPEN — No Sun Park-to-Orion cash or asset transfer is established by this comparison. The missing evidence would be an actual account, contract, payment, loan, guarantee or asset transfer.
These are tests of Por Derecho’s attributed criminal hypothesis concerning Community records, authority, seizure and obstruction of a funded exit. They do not declare that every step is proved.
Identify the original, date, version and alleged falsity.
Separate author, signatory, instructor, recipient and decision-maker.
Establish the required mental element from actor-specific evidence.
Trace actual submission, receipt, review and reliance separately.
Identify how the act changed possession, a decision, cost or recovery.
Trace beneficiary and recoverable harm; avoid double counting.
CONTRARY / PROCEDURAL OUTCOME — Current controls record DP1956’s provisional dismissal on 21 July 2026 and inadmission/adverse review in the Audiencia Nacional route. Exact scope matters. These are neither convictions nor a complete merits trial.
This visual uses the linked public interview, the preserved webinar/source controls and issuer disclosures. It is an editorial evidence map, not independent adjudication. The complete accompanying chapters preserve each allegation, qualification and source.
SATIRICAL / CARICATURE REPRESENTATION — NOT A REAL ADVERTISEMENT
INDEPENDENT POR DERECHO EDITORIAL RECONSTRUCTION — NO OFFER, NO REAL ISSUER ADMISSION, NO REGULATORY APPROVAL
12 September 2026. This supplement expands The Memorandum That Discloses the Case File. It preserves that publication's fictional-issuer distinction, source register, contrary evidence and correction policy. Its purpose is to demonstrate what a candid, evidence-based account of the relevant history would need to address. It is not written or authorised by Orion Rental SOCIMI, RICPE, Portfolio or CNMV.
The passages headed “A candid disclosure would explain” are Por Derecho's proposed disclosure language. They are neither quotations nor admissions by the real parties. The factual comparisons identify dated source statements; the allegations identify their author; unanswered questions remain unanswered. A later event is not silently inserted into what someone supposedly knew in 2020 or 2024.
A candid disclosure would explain:
Our history includes investment presentations made before all the Sun Park acquisition and due-diligence conditions were satisfied. A reader needs the conditions as prominently as the opportunity. We would identify the exact properties covered by each ownership assertion, the date at which acquisition became effective, the charges and third-party rights that remained, which diligence reports were complete and which were still promised. We would show the corrections delivered before commitments, subscriptions and drawdowns.
Contrary evidence that belongs on the same page: the 2020 brochure expressly describes projects under study; the presentation includes conditions and duties of means rather than guaranteed results; the July 2021 certificate distinguishes ownership of an operating establishment from ownership of every property. Fragmented title alone does not make every financing structure unlawful. The investigative question is the accuracy and overall impression of the particular communications, assessed at their dates. [E1–E4]
A candid disclosure would explain:
A professional firm that introduces clients into an investment is part of the investment's factual history. If a partner of that firm simultaneously administers an insolvency involving assets material to the connected project, our conflict account would identify both functions, the relevant legal entities and periods, who acted for whom, who received which information, remuneration, recusals and the safeguards actually used. We would explain the outcome of that review.
In the 2021 interview, Eduardo Sánchez Iglesias, San Telmo's tax partner, says at 08:08–08:12: “bueno nosotros en el despacho en esa / primera inversión de la que hablas de / hacer pues metimos unos cuantos clientes”. The firm-introduction acknowledgement is supported; the exact subscriptions, project allocations and legal character of the service require records. [E1–E2]
San Telmo's archived September and December 2021 team pages list the insolvency administrator Francisco de Borja Rodríguez-Batllori Laffitte as a legal partner, Eduardo as a tax partner, and a separate Javier Rodríguez-Batllori Laffitte partner. The latter full name is reproduced as the archived firm's source description. Gil Marer identifies Javier as the administrator's brother; the family relationship has not been independently verified in this review. The contemporaneous firm partnership evidence does not depend on establishing kinship. [E2]
This is a concrete institutional conflict inquiry. It is not proof that every partner saw the insolvency file, that San Telmo itself invested capital, that all introduced clients financed Sun Park, or that a prohibited act occurred. The separate historical question whether Guerra and the administrator were simultaneous A&G partners in the same legal entity remains unproved. A&G advisory entities, A&G Capital and Acosta Matos Gestión/AGM must remain distinct. [E2–E3]
The earlier PwC engagement and contact with the administrator matter because knowledge can precede a later investment role. Gil Marer's specific account that PwC told the administrator criminal action was required remains an attributed recollection requiring the exact words, participants, date and corroboration. A later RSM integration or a Grant Thornton audit engagement cannot automatically transfer all earlier knowledge or liabilities across people and legal entities. The requested disclosure is the engagement and knowledge chronology, with the actual conflict decisions. [E3]
A candid disclosure would explain:
Serious allegations concern the means by which private interests acquired or exercised apparent authority over the Sun Park Community, its records, access and economic decisions, and the alleged consequences for an operating business, an insolvency estate and an available funded exit. We would describe the particular allegations against persons who later became relevant to our governance or management, their responses, the proceedings and outcomes, and the independent reasons for judging their materiality to this investment. We would not require a reader to infer that history from a family ownership table.
Por Derecho alleges a connected mechanism: disputed appointments, voting exclusions, debt figures and minutes → apparent Community authority → access/security, works and uses in insolvency or administrative processes → economic benefit and obstruction of recovery. This is an attributed criminal hypothesis, including alleged knowing falsification and use of false documents, not a finding that every link has been proved. It includes the allegation that the 7 June 2018 forced seizure obstructed the funded exit and the formal completion steps; the absence of a completed exit filing must not be presented as an unexplained omission by the displaced operator. [E5]
For each actor, criminal attribution requires the act, capacity, document, alleged falsehood, knowledge/intent where required, use, causal effect and benefit or harm. A family relationship, later board appointment or favourable judicial order cannot replace that proof. The existence of lawful appointments, genuine costs, necessary limited security measures or works confined to lawfully controlled units must be tested as competing explanations. [E5]
Procedural outcomes also belong here. Current controls record the 21 July 2026 provisional dismissal of DP1956, without establishing a filed appeal, and inadmission/adverse review in the Audiencia Nacional route. These are not convictions or a completed merits trial. The precise scope of each outcome must accompany the allegation. Orion was formed in 2023: it cannot have committed an act in 2018. Any later responsibility must arise from its own conduct, duties or legally established consequences. [E5–E6]
A candid disclosure would explain:
We would place the 2018 premises transaction, the 2019 refusal to convalidate, the subsequent proceedings and favourable decisions, the 2022 title and the 2023 security in one dated account. We would identify what was reversed in practice, what was not, which properties and prices were affected, and what each later decision actually resolved. We would explain the legal OB REM link separately from physical building works.
For the Sun Park branch, the controlled reconciliation attributes €6,573,703.10 to RICPE/HNT/MYND in the 2023 accounts, with detailed component allocation still open. The register identifies Cajasiete mortgage charges in 2023; that does not prove that Cajasiete paid the 2018 purchase price. Regional incentives, FEDER/ERDF-related funding, RIC tax materialisation, equity and loans are separate regimes and instruments. [E5, E7]
The proper exhibit is an invoice-level reconciliation: property/work → cost → payer → instrument → drawdown/payment → eligible amount → declaration to each authority → actual beneficiary. Multiple funding sources alone do not prove double funding. Conversely, a grant award, tax report or later opening does not establish the accuracy of every underlying title, authority, invoice or declaration. Alleged false submissions to Yaiza, Cabildo or funding bodies require the exact submitted document and its decision trail. [E5, E7]
For Orion, the updated memorandum reports a different branch: a RICPE participating loan dated 30 December 2024, €6,385,844 drawn by end-2025 and an €8.5 million ceiling; CAM construction billing of €7,126,468.39 in 2025; and changes to the property portfolio and conditional grant. These are disclosed figures, not newly audited cash flows. A common platform and overlapping actors do not establish a Sun Park-to-Orion transfer. Its existence or absence requires actual account, contract, loan, guarantee or asset-transfer evidence. [E4, E7]
The pending CaixaBank Valencia matter must be presented through alternative outcomes: dismissal or unsuccessful claim; negotiated settlement with specific releases and beneficiaries; favourable judgment subject to challenge and collection; or a narrower recovery. Standing, liability and quantum are contested. Recovery for LPB's estate is not automatically unrestricted money for shareholders, a reversal of the hotel adjudication or proof of Portfolio liability. The same loss must not be counted twice. [E3]
A candid disclosure would explain:
Our memorandum identifies important ownership and family relationships. We would also explain the operational conflicts, relevant earlier conduct, known disputes and financial consequences those relationships may create. The test is not whether a name appears somewhere. It is whether the account enables a reader to understand a material risk and the measures taken to address it.
The original Orion document already identifies Guerra's PwC history, Acosta Matos/AGM interests, FMMM's Pamalexsha interests and powers, the Cogolludo family relationships and interests, and Cajasiete's 5% position at the stated date. Its annex describes Cajasiete's board attendance with voice but without a vote. These items should not be called wholly hidden. The biography/history, investor-introduction, conflict and materiality questions remain. [E4]
The original no-litigation statement is tied to litigation capable of affecting the issuer's results. A complaint against a director does not automatically falsify it. The 2026 document also contains litigation and risk wording, and the 2025 accounts have an unmodified EY audit opinion. Those facts are part of a fair assessment; neither is a universal clearance of every alleged earlier act. The inconsistent first-tranche share figures should be reconciled on their own documentary merits. [E3–E4]
A candid disclosure would explain:
Our correction would identify the original statement, the dated source, the finding, the corrected wording and the affected decision. It would state whether the issue was an error when published, an omitted material fact then known, or a later development. It would reach the audiences to whom the material account was given, including identifiable webinar, referral and later investment audiences where appropriate. It would retain prior versions and provide a clear account of unresolved questions and responses.
Por Derecho asks Portfolio's board and compliance function together to appoint an appropriately independent review, preserve the relevant files, determine each materiality question and explain the action taken or reason for declining it. The issuer's corrected memorandum, any accounting restatement and Portfolio's own public notice are different measures. An accounting restatement requires an accounting basis; suspension or other market measures require the applicable conditions and a competent decision. [E3–E4]
Portfolio has acknowledged communications and reported review steps, including a September 2026 transmission to CNMV. The demand is for an adequate, reasoned outcome and necessary correction, not an inaccurate assertion of total silence. Foreign investors, directors, service providers or UK recognition must be described through verified legal entities, dates and activities; they do not establish jurisdiction or responsibility merely by association. [E3]
The transparency test: Can the reader distinguish what was known then, what became known later, what was disclosed, what is alleged, what was decided against the complainant, and what remains to be produced? If not, another reassuring sentence is not the missing document.
This public supplement does not reproduce private correspondence, client identities, mailbox identifiers or private source links. Precise underlying records should be supplied through a controlled evidence channel where lawful and appropriate. Corrections and substantive replies should be recorded beside the affected proposition and dated edition.