Certification on risk administration system to prevent money laundry

of the customer and of his operations with our entity, products, distribution channels and jurisdictions, transactions monitoring, personnel training and suspicious operations reporting to the competent authorities. The businesses and operations of the Bank are transacted within ethical and control standards, placing healthy banking practices and practices addressed to the prevention of Money Laundry and Terrorism Financing before the achievement of business goals.<br><br> The procedures and behavior regulations regarding the application of all SARLAFT mechanisms and control instruments are contemplated in the SARLAFT Manual and in the Ethic Code approved by the Board of Directors, which are of obligatory observance by all the employees in the Bank. KNOWING OUR CLIENTS Our policy of client knowledge seeks to properly identify all our clients for the purpose of establishing their financial profiles. Some clients, due to their high risk profile must comply with more demanding client knowledge processes.<br><br> Clients 9 and counterparts information is verified and we perform procedures addressed to maintain the information of such clients updated. In addition, our Entity has developed a policy related to the provision of correspondent banking services that establishes, for example, not to offer our Entity services to the so called cfaçade banks d or cshell bank d. All this is complemented with the knowledge of the market segments and the clients we attend, which allow us to make comparisons regarding the clients we engage.<br><br> The information of our clients is kept during the periods of time provided by the law and it is available to the authorities for the purposes of their investigations. MONITORING SYSTEM Our Entity monitors the transactional behavior of our clients, products, channels and jurisdiction, which purpose is to identify possible unusual operations, on the basis of the alert signals established. For a certain type of clients, with a higher risk profile, a more detailed monitoring schema has been established.<br><br> . In accordance with our client 9s knowledge policies, once an analysis of unusual operations is performed, and in the event of determining that said operations are suspicious, they are reported to the competent authorities (UIAF), in a form established by the regulation. PERSONNEL TRAINING Our institution Senior Administration is aware of how important training is and it understands the employees are fundamental in our fight against Money Laundry and Terrorism Financing.<br><br> Generally, all the institution 9s employees are trained on Money Laundry and Terrorism Financing Risk Administration System. When undergoing induction, specific programs are designed according to the role each employee is going to perform. Additionally, those employees in direct contact with clients, as well as those who manage relations with clients defined as of higher risk, receive constant training on this matter.<br><br> COMPLIANCE OFFICER For the performance of the duties established by the legal regulations, the Board of Directors has appointed a Compliance Officer and his Deputy, who are duly recorded with the Colombia Financing Superintendence. This Compliance Official is a second hierarchical level official in the Entity, who has decision making capacity and is supported by a human and technical work team that allows her to cover the different management areas, and she is also supported by the Entity 9s Directors. CONTROL AND AUDIT The compliant revision of the control mechanisms designed and implemented at the Control and Compliance Vice Presidency and other areas in the Entity, have been included in the internal audit processes as a verification specific program.<br><br> In accordance with the directions given on this matter by the Financial Superintendence of Colombia, the Statutory Auditor 9s Office, an external control entity in the Bank, has the respective validation controls instrumented, which allow it to detect the non-compliance of instructions that for the prevention of money laundry and terrorism financing are consecrated in the EOSF (Financing System Organic Statue) and other legal regulations. We are subjected to the supervision and inspection of the Colombian Financial Superintendence, which must verify the implementation of the SARLAFT in our Entity. As a result of such evaluations, correctives are applied allowing a continuous improvement on this matter and facilitates our institution to mitigate the risks of money laundry and terrorism financing.<br><br> CLAUDIA A. JIMENEZ Compliance Officer

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