Research

INTRODUCTION

The objective of this document is to promote ethical behavior among all the members of LATIN SECURITIES S.A. CORREDOR DE BOLSA (hereinafter the "staff" and the "Broker", respectively), establishing principles and standards of conduct that will govern the actions of our organization.

The Board of Directors of LATIN SECURITIES S.A. CORREDOR DE BOLSA is responsible for ensuring the updating of this document, as well as promoting its communication among all staff. The enunciation of rules, principles and duties established in this Code does not imply the ignorance of others inherent to the purposes of law.

SCOPE

The Code of Ethics and Standards of Conduct is mandatory for all the Broker’s personnel: its Board of Directors, Management, Departments and Administrative staff. In this sense, all must contemplate and apply the conduct guidelines and ethical principles contained in this Code.

DEFINITIONS

For the purposes of this Code, the following definitions shall apply:

Stock Market is the place or scope of negotiation of public or private securities offering. It provides its members with the necessary means to effectively carry out securities transactions through public auction mechanisms, and to carry out the rest of the brokerage activities that proceed in accordance with the law and regulations.

Securities refer to goods or transferable rights, incorporated or not in a document. That is: shares, negotiable debt obligations, futures markets, options, investment fund shares, securities and, in general, all creditors or investment rights.

LATIN SECURITIES S.A. CORREDOR DE BOLSA Authorities are all those people who - given the position they occupy in the institution - hold the quality of Senior Personnel, in accordance with the Central Bank regulations.

Advice: The Advisory service involves advising clients regarding the investment, purchase or sale of money, precious metals or securities subject to public or private offering, or about the appropriate composition of their investment portfolio, and the channeling of their instructions to institutions in the country or abroad.

Privileged Information refers to the information of an issuer -or the securities that he issues- obtained by reason of his position. It also refers to the information transmitted by a client in relation to his own pending orders, which has not been made public and which, if made public, could significantly influence the price of the issued securities or their derivatives. Likewise, privileged information is the one obtained from the transfer of ownership operations to be carried out by an investor in the stock market, in order to obtain advantages with the negotiation of securities.

Market Manipulation refers to the performance of practices that distort the free formation of prices. Market manipulation will be configured when, among others, any of the assumptions detailed below are verified:

• Carrying out operations that are intended to provide false or misleading indications regarding the supply, demand or price of the securities.

• Carrying out simulated operations, or the use of any element, scheme or device with the aim of deceiving people about the true state of demand and supply of a security.

• Dissemination to the public - through any means - of false or misleading information about issuers and their securities.

• The deformation or concealment of facts or circumstances relevant to the negotiation of a public offering security.  

Lack of loyalty and business ethics: there will be a violation of the duty of loyalty and business ethics when, among others, any of the following acts are carried out:

• Causing an artificial evolution of prices for one’s own benefit or that of others;

• Multiplying transactions unnecessarily and without benefit for the client or the managed funds;

• Acquiring for oneself one or more securities when having clients who have requested them in identical or better conditions, or to the detriment of the managed funds;

• Selling ones’ own securities before those of the clients when they have ordered to sell the same kind of security under identical or better conditions;

• Acquiring securities for clients that were originally intended to be acquired for oneself, based on less favorable market circumstances.

PRINCIPLES AND VALUES OF LATIN SECURITIES S.A. CORREDOR DE BOLSA

The performance of the Broker’s staff must always be based on integrity, trust, loyalty, full respect and recognition of the intrinsic value of the human being. Any prejudice of race, religion, origin, social class, sex, physical disability or any other form of discrimination is rejected, however, any person who intends to defend or enforce their rights, which they consider violated, must do so with respect for the organization, its officials and the work carried out in it.

In general terms, all the Broker’s personnel must:

• Watch over the interests of clients and treat them fairly, giving absolute priority to their interests and minimizing the risks of conflicts of interest. Conflicts of interest must be defined and identified and, in such situations, privileging any particular client will be avoided.

• Act with professionalism, care and diligence, both within the Broker and with regards to customer relations and other agents with whom they interact.

• Provide advice with loyalty and prudence, acting with integrity, avoiding any type of discrimination.

• Provide clients with all the necessary information on the services offered, in a clear, truthful, precise and timely manner, avoiding the omission of essential data, so that they can make decisions with great knowledge of the characteristics and risks of the operations.

• Act with professionalism, care and diligence with clients, in accordance with the uses and customs of the business, applying a great sense of justice and clarity in all channeling.

• Observe the laws and decrees that govern securities intermediation activity, as well as the general regulations and specific instructions issued by the Superintendence of Financial Services (SSF).

• Inform the Central Bank of Uruguay (BCU) about violations of the regulations mentioned in the previous point.

• Observe the rules and regulations issued by the Bolsa de Valores de Montevideo.

• Provide clear procedures for the resolution of possible differences with clients.

• Refrain from misusing privileged information.

• Run orders received from customers diligently under the terms in which they were given.

• Refrain from unnecessarily multiplying transactions without benefit for their clients, from executing fictitious or simulated operations, from assigning to themselves one or more traded securities when they have clients who have requested them in identical or better conditions, and from misleading through false declarations.

In the development of the Broker's own activities, its personnel are expressly prohibited from engaging in market manipulation.

STANDARDS OF CONDUCT

All of the Broker’s personnel must adhere to the conduct rules contained in this Code, namely:

• Observe current legal and regulatory standards and healthy market practices. The Broker's staff, in the development of their professional activities, must fully comply with the laws and decrees that govern securities intermediation, with the general rules and particular instructions issued by the SSF of the BCU and with the rules and regulations of the BVM.

• For this purpose, it is vitally important that all participants have a solid knowledge of the rules that regulate their activity. In this sense, the Broker must keep its personnel adequately trained regarding the regulatory framework applicable to its specific activity.

• In accordance with this principle, staff should:

• Refrain from carrying out any operation, act or contract that involves a breach of the legal and regulatory framework in force, the regulations adopted by the Broker or healthy market practices.

• Supervise that the development of daily activities takes place in accordance with the legal and regulatory framework in force and healthy market practices.

• Provide the Market with clear, truthful, complete and timely information. The information provided to investors must be clear, truthful, complete and timely, so as to allow them to make decisions with knowledge of the characteristics and risks of the securities or instruments object of the investment. In no case will inaccurate references or expressions likely to generate error, deception or confusion in investors be used.

• Prioritize the interest of the client. The staff will give absolute priority to the interest of the client, acting with integrity, loyalty and transparency. When investment advice is provided, it will be provided promoting the client's interests and taking into account the client's investment characteristics and objectives.

• Avoid conflicts of interest. The staff will avoid placing themselves in situations that could mean a conflict between their personal interests - or those of people or entities closely related to them - and those of the Broker. In order to prevent conflict situations, they must refrain from approving, granting, participating or exercising influence to approve operations, services or businesses with clients or suppliers with whom they are linked, nor participate in transactions in which personal interests may collide with the efficient and complete operation of the stock market, or with the interests of the Broker.
• Personnel must bear in mind that they must promptly disclose any situation that - in the performance of their activities - could affect their professional objectivity or imply a conflict of personal interest.
• Maintain the confidentiality of the information. All personnel must maintain the confidentiality of all non-public information obtained or generated from their professional activities, even after they have left their position. In this sense, they will be obliged to keep strict confidentiality about the information of customers and operations that come to their knowledge due to their functions, and that have not been disseminated.

• Information regarding clients and operations may only be disclosed upon an express and well-founded request from the Competent Authorities, in accordance with the current legal framework.

• Prohibition of the use of privileged information. Staff may not use privileged information that they have learned on the occasion of their duties, in order to obtain benefit for themselves or for a third party.

• In this sense, those who access privileged information shall refrain from executing - on their own or on someone else’s behalf - the following activities:

• Reveal inside information before it is released to the market.
• Recommend the execution of operations with securities on which there is privileged information.
• Carry out any type of operation, for themselves or for third parties, directly or indirectly, with the securities or financial instruments about which they have privileged information.
• Using privileged information directly or indirectly, for their own benefit or that of third parties.
• In particular, shareholders, directors, managers, auditors, senior staff and advisors must refrain from carrying out the aforementioned activities. The handling of privileged information will always be carried out in accordance with the regulations issued by the Central Bank of Uruguay and in compliance with the internal procedures established by the Broker (Annex 1).
• Prohibition of incurring in Market Manipulation. All the Broker's personnel are prohibited from adopting market manipulation behaviors and consequently, they must refrain from:
• Carrying out operations that are intended to provide false or misleading indications regarding the supply, demand or price of the securities.
• Carrying out securities transactions in order to stabilize, fix or artificially vary prices.
• Making fictitious or simulated orders, quotes or transactions.

• Carrying out simulated operations, or using any mechanism or device with the aim of deceiving the true state of demand and supply of a security.

• Spreading false or misleading information, news or rumors, with the intention of misleading the market, even when this does not seek to obtain a benefit for themselves or a third party.

• Disseminating - through any means - information that may be misleading about the nature, prices, profitability, redemptions, liquidity, guarantees, or any other characteristic of the public offerings or of their issuers.

• Hiding or distorting relevant facts or circumstances for the negotiation of a public offering.

• Providing false information or certifying false facts about carried out operations.

• Loyalty. The Broker's staff must adopt honest and equitable behavior among themselves, avoiding commercial, professional or personal disloyalty. Care must be taken that competition between colleagues is conducted fairly and in good faith.

• Communication with the Superintendence of Financial Services. The Broker will comply with the announcements of periodic or exceptional reports made by the Superintendence of Financial Services.

• Responsibility and Professionalism.  The Broker’s staff shall act with professionalism and discretion, showing skill and dedication in all aspects within their area of responsibility.  

• Relationships in the workplace. The Broker authorities express their commitment to creating a pleasant professional work environment where courtesy, loyalty and mutual respect prevail. In this framework, all employees will be treated impartially, avoiding unequal treatment based on any cause of discrimination. All personnel will act with respect, loyalty and impartiality and will refrain from granting favors or special privileges to any person or entity.

  • Professional activities outside the Broker. Staff may carry out other professional activities external to the Broker provided that they allow them to effectively fulfill the functions inherent to their position, not limiting the required time availability.

• Nevertheless, the Broker's officials may not develop external professional activities in favor of an entity that performs competitive activities with the Broker. Nor will they be able to carry out professional activities on a regular basis, for other Stock Brokers, Issuers of Securities, or suppliers of the Broker.

• Before accepting or carrying out any professional activity outside the Broker, whether regular or occasional, the official must formally notify his hierarchical superior.

• Policy regarding personal investments. The authorities and employees of the Broker may not carry out - on their own account or on behalf of people with whom they share economic interests (family, others) - the following financial operations:

• Operations that interfere with or affect the work or dedication of the employee.

• Transactions carried out using privileged or relevant information obtained from their activity within the Broker.

• Investments in financial instruments issued by companies, if said investment could affect their ability to make impartial decisions in the Broker.

• Representation of LATIN SECURITIES S.A. CORREDOR DE BOLSA. No employee may invoke the name of the Broker without authorization or being qualified to do so. Also, if an employee is planning to participate in lectures, interviews or public presentations related to the activities of the Broker, he must obtain prior formal authorization from the Board.

• Reporting Channels. Staff who become aware of the existence of situations that violate the current legal and regulatory framework, or situations that are incompatible with the Broker's ethical values, must report them to the Broker's General Management immediately, providing all the information and documentation they have.

 • Gifts and gratuities. Broker employees may not accept or grant gratuities, gifts, or participate in invitations whatever their nature or origin. However, modest and customary gifts in business relationships with other market participants may be accepted.

• For these purposes, the gift or gratuity must meet the following criteria:

• It should represent an insignificant economic value,

• It may not be done in the form of money or negotiable securities,

• It must be limited to commercial practices recognized and accepted by all,

• It may be disclosed without embarrassing situations for the Broker or the beneficiary of the gift.

​GENERAL POLICIES.

COMPLIANCE WITH LEGAL, REGULATORY AND STATUTORY PROVISIONS

As stated above, this Code contemplates and abides by the current legal regulations, so that all Broker’s employees, without any exception, will be subject to what is established here, and, therefore, must adjust and guide their conduct towards their proper compliance.

The staff will duly comply with all the rules that regulate the development of businesses and processes. Each employee must acknowledge all the provisions related to his position upon joining the organization, as well as their subsequent updating.

In order to maintain the standards of professionalism and ability of the Broker, the selection of personnel will be carried out taking into account - at the least – guidelines of experience, ability and moral solvency to guarantee optimal performance in the assigned functions. Likewise, the Broker will use tools to keep his staff updated on issues related to stock market activity, maintaining their technical and professional update levels.

The Broker will be responsible for the actions of its personnel. As a result, it will use the necessary means to ensure that any person, legal representative or not, who engages the Broker in a specific business, has the necessary powers to do so. To do this, it will adopt adequate and sufficient control measures to avoid that, in the normal development of its operations, it is used as an instrument for the concealment, management, investment, or use in any way, of money or other assets from criminal activities, or to give appearance of legality to criminal activities, transactions and funds related to them. 

COMPLIANCE WITH MONEY LAUNDERING PREVENTION AND CONTROL PROCEDURES. 

On account of the proactive action imposed by the new market reality, national and international regulation, and the intangibility of the financial system itself, the Broker has formalized its commitment to society by preparing this conduct guide and a Manual for the Prevention of Money Laundering and Countering the Financing of Terrorism.

The above mentioned Manual contains clear principles of professional ethics and commitments, namely:

• Policies and procedures for ML and TF risk management in order to prevent, detect and report unusual or suspicious operations to the UIAF. In particular, the adoption of due diligence policies and procedures regarding the clients, so as to obtain an adequate knowledge of them, paying special attention to the volume and nature of their economic activities, as well as identifying the final beneficiary of the funds or values applied to the operations.

• Policies and procedures regarding personnel that ensure a high level of integrity, as well as their permanent training and updating in the matter.

• An adequate organizational structure for compliance, with the appointment of a Compliance Officer, responsible for the implementation, monitoring and control of the proper functioning of the prevention system.

Additionally, the Broker complies with the procedures and rules established by the Montevideo Stock Exchange (BVM). In this sense, when they channel transactions through the BVM and in particular, when they use its accounts for the transfer and / or receipt of funds or securities, they will comply with the information requirements established by BVM. 

FRAUDULENT AND ILLEGAL ACTS

In the event of acknowledging or presumption of a fraudulent or illegal act in which one or more of the Broker's staff members have participated (together, in collusion with third parties, or on their own), the corresponding legal process must be applied,  having to efficiently cooperate with the judicial authority to facilitate the correct application of the Law.

All members of the Broker, to the extent of their functions and attributions, must seek to reverse the damage that has been caused to the organization, as well as to watch over its interests. 

ADMINISTRATIVE IRREGULARITIES

It is the responsibility of the Broker to have training programs, updated methods and procedures for control, design and disseminate security measures, and it is the responsibility of the staff to comply with such programs and guidelines.

The staff who commit irregularities due to ignorance, distraction, negligence or poor performance in their functions - without intent or bad faith - but causing damage to the Broker's assets, will be applied the corresponding administrative or criminal sanctions, as none of the mentioned causes will release them from responsibility.  

DUTIES AND RESPONSIBILITIES OF THE STAFF OF LATIN SECURITIES S.A. CORREDOR DE BOLSA AS TO THE INFORMATION PROVIDED BY THE CLIENT.

The Broker will handle the information provided by the clients with the strictest confidentiality, making every effort to avoid disclosures, intentional or not, without the express and written consent of the clients. At a minimum all of its staff must: 

• Lock up all customer-related and other potentially confidential materials in desks or filing cabinets.

• Keep the information on its personal computers under strict control, with access codes to the information on hard drives and on the network.

• Ensure security and privacy in the negotiation areas.

• Control access to office areas containing confidential information after working hours.

• Control at all times the entrance to the archive rooms.

CLAIMS MANAGEMENT

The Broker will provide a claims service, through which queries submitted by Clients may also be channeled. Claims will be dealt with diligence, willingness, and an effort to obtain the most information to be able to solve them as soon as possible, complying with the deadlines set in the applicable regulation.

Clients will also be informed, when required, about the claims procedure and response times for each case.

 The claims system adopted by the institution will be made known to the Clients on the website and the offices, as well as through the officials themselves.

For this, the Broker has a person in charge of the claims service, who for all purposes will be in communication with the requesting client, and see to the correct procedure.

SANCTIONING REGIME

Failure to comply with the provisions established in this Code by the Broker's staff will be subject to the application of administrative sanctions, without prejudice to those of a civil or criminal nature that may correspond in accordance with the laws of the Republic and / or other applicable regulations.

According to the sanctioning regime, the violation of any of the provisions of this Code is considered a fault, be it culpable or fraudulent.

A negligent act is when, due to lack of skill, negligence or inattention, any of the provisions of the Code are violated, without there being a will to violate it.

A fraud exists when:

 • There is awareness and willingness to carry out an operation knowing that it implies a violation of the provisions contained in this Code or the legal and regulatory framework in force in our country;

• There is awareness and willingness to carry out an operation, without the intention of violating the rules of this Code, but knowing that, ultimately, a result may occur that involves the violation of the rules contained therein or of the legal rules and regulations that govern in this country.

Any fault, guilty or fraudulent, will determine the application of a sanction, which will be graduated according to the seriousness of the offense and the will of the person who carried it out.

The following sanctions may be applied, which must be substantiated in all cases:

• Observation.

• Warning.

• Fines of up to U.I. 1,000,000.

• Suspension.

• Dismissal.

Misconducts committed with intent will be considered serious offenses in all cases. When there is a presumption of the commission of a crime, justice will be notified immediately.

Sanctions will be imposed by the Board of Directors, through a founded resolution and in accordance with the established disciplinary procedure (attached as Annex 2).

UPDATING AND COMPLIANCE WITH THE CODE OF ETHICS AND RULES OF CONDUCT

This document will be distributed by means of a memorandum addressed to all of its personnel, each official having to sign the corresponding proof of receipt, with the commitment acquired for its fulfillment.

Each time a modification is made to this Code, the updated version will be disclosed once it is approved by the Board of Directors and put into the respective Minutes.

All personnel who become part of the Broker after the approval of this Code, must sign said certificate at the time of their appointment or hiring. 

ANNEX 1

PROCEDURES FOR THE PREVENTION OF THE FLOW OF PRIVILEGED INFORMATION AND INTERNAL PROCEDURES FOR THE FORMULATION OF COMPLAINTS

INTRODUCTION

In compliance with the provisions of the Collection of Securities Market Regulations of the Central Bank of Uruguay, and especially with regard to the Prevention of the flow of privileged information and internal procedures and protection for the formulation of complaints of the Collection of Regulations of the Central Bank of Uruguay, the Board of Directors of Latin Securities SA Corredor de Bolsa prepares this procedure in order to promote the proper handling of privileged information as well as to establish safe mechanisms for the formulation of complaints.

SCOPE

This procedure covers all the Broker’s staff.

DEFINITION OF PRIVILEGED INFORMATION Privileged information is the information of an issuer - or of the securities it issues - obtained by reason of the position, including the information transmitted by a client in relation to his own pending orders, which has not been made public and which, if made public, it could significantly influence the price of the issued securities or their derivatives.

Likewise, privileged information is the one obtained from the transfer of ownership operations to be carried out by an investor in the stock market.

The information available in the Broker's computer systems related to the holding of securities, related parties in transactions, evolution of transactions for one or more securities is considered privileged information and therefore cannot be disclosed. The handling and safeguarding of said information will be carried out with the maximum security conditions.

MISUSE OF PRIVILEGED INFORMATION

The Compilation of Securities Market Regulations of the Central Bank of Uruguay, establishes that the actions established below constitute improper use of privileged information:

• Reveal or trust inside information before it is disclosed to the market

• Recommend to carry out operations with securities about which there is privileged information.

• Acquire or dispose of for oneself or for third parties, directly or indirectly, securities about which one has privileged information.

• In general, use inside information directly or indirectly, for one’s own benefit or that of third parties.

Directors, Managers, Auditors, Commercial Sector or Senior Personnel and, in general, any person who, by reason of their position, has privileged information, must refrain from taking the actions detailed in the previous paragraph.

GENERATION AND RECEPTION OF PRIVILEGED INFORMATION

Whoever has the power to generate privileged information, must make its condition known to its recipient through labels that identify the confidential or reserved nature of the information.

Access to the information of the counterparties of the operations carried out in the Broker will be restricted to the personnel who, for the performance of their tasks, require access to it and to the parties involved in the transaction. The information available in the Broker's computer systems related to the holding of securities, related parties in transactions, evolution of transactions for one or more securities is considered privileged information and therefore cannot be disclosed. The handling and safeguarding of said information will be carried out with the maximum security conditions.

CUSTODY OF PRIVILEGED INFORMATION

Privileged information must be received by the Broker's superior staff, who will keep it confidential or reserved until the information ceases to be privileged or reserved.

The documentation received must be kept in a place with restricted access.

PRIVILEGED INFORMATION: PROHIBITIONS AND DUTIES.

The Broker and all personnel with privileged information:

• They may not use it for their own benefit or that of others, nor carry out any business, for themselves or for third parties, directly or indirectly, concerning the securities on which they have privileged information.

• They must keep strict reserve regarding privileged information, refraining from communicating it to third parties.

• They may not use inside information to obtain profits or avoid losses, for themselves or for third parties, through any type of operation with the securities to which it refers, or with instruments whose profitability is determined by those values.

• They will refrain from recommending the acquisition or sale of the securities about which they have privileged information.

• They must ensure that the communication of privileged information or the recommendation of acquisition or sale of the securities on which they have privileged information does not occur through their subordinates or trusted third parties.  

MARKET MANIPULATION

The following behaviors identify prohibitions and duties that apply to the Broker and all its personnel, in relation to market manipulation behaviors:

• They may not carry out securities transactions in order to stabilize, fix or artificially vary prices.

• They may not carry out transactions or induce or attempt to induce the purchase or sale of securities, by means of any act, practice, mechanism or artifice, whether they know, or should reasonably know, that it is deceptive or fraudulent.

• They may not carry out fictitious or simulated orders, quotes or transactions.

• They may not carry out any act or disseminate false, misleading or tendentious information, news or rumors, with the intention of misleading the market, even if this does not seek to obtain advantages or benefits for themselves or third parties.

• They may not carry out publicity, propaganda and dissemination, whatever the medium, that contain statements, allusions or representations that may mislead or confuse the public about the nature, prices, profitability, redemptions, liquidity, guarantees or any other characteristics of public offering securities or their issuers.

• They may not provide false information or certify false facts, regarding the operations carried out or in which they have intervened.

TRAINING

The Broker must ensure the training of its employees in the handling of privileged information as well as market manipulation behaviors.

COMPLAINT PROCEDURE

Those who wish to file a complaint associated with the handling of privileged information or market manipulation, must make it in writing to the Compliance Officer, as described in Annex 1 of the Manual for the Prevention of Money Laundering and Terrorism Financing.

Communications will be made using the "Delivery Confirmation" and "Reading Confirmation" options, in order to ensure reception and reading by the Compliance Officer.

Internal communication shall inform: 

• Identification of the natural or legal person(s) involved in the operation, how they relate to each other, and the nature in which they participate.

• Description of the transaction or transactions about which there is suspicion.

• Details of the circumstances or reasons that led to classify these operations as suspicious, attaching a copy of the actions related to the investigation carried out.

For all complaints filed, the response to the complainant will be in writing, to the address that appears in the note of the complaint. 

ANNEX 2

DISCIPLINARY PROCEDURE OF LATIN SECURITIES S.A. CORREDOR DE BOLSA

SCOPE OF APPLICATION

The disciplinary procedure set forth herein shall be applied whenever there are sufficient grounds to impose a sanction on any of the Broker's staff members. In this sense, all of them will be subject to the application of the procedure set forth herein.

Without prejudice to others not necessarily listed below, the following will be considered sufficient reasons:

• Non-compliance with internal regulations.

• The performance of notorious acts that involve serious ignorance of morals and good customs.

• Carrying out fictitious or simulated transactions regarding any security.

• Failure to complying with the conditions agreed in the operations carried out.

• The use of privileged information for their own benefit or that of related third parties, which has not yet been officially disclosed to the market, and which is confidential.

• The formulation of investment recommendations that are not based on well-founded and objective information, and those that guarantee benefits or promise returns for investments.

• Carrying out any advertising and dissemination of misleading or false information, which contains statements, allusions or representations that may lead the investor to error, mistake or confusion about the nature, prices, profitability, redemptions, liquidity, guarantees or any other characteristic of the securities that are traded, or the issuers thereof.

• Lack of compliance, or proceeding in bad faith in contracts in which one intervenes directly or indirectly.

• Criminal conviction issued for acts that threaten the reputation or honor of the person.

• Carrying out acts or operations contrary to the interests of the Montevideo Stock Exchange and/or its Code of Ethics.

STRUCTURE OF THE DISCIPLINARY PROCESS

Principle of Due Process

In all actions of the disciplinary process, the principle of due process must be applied and respected. The parties subject to the procedure must have all the rights and guarantees inherent to the aforementioned principle.

If said principle is not complied with in any of the instances, all the actions will be void.

Effects of the Sanction

The sanction will be applicable immediately once it has been resolved, and no recourse against it will be admitted.

Confidentiality

All actions carried out in compliance with the disciplinary process will be reserved and confidential, and they cannot be disclosed to any person outside the procedure, unless authorized to do so by any of the parties.

The obligation set forth in this article shall be extended to all persons who participate directly or indirectly in the procedure.

DISCIPLINARY SANCTIONS

Applicable sanctions

The following sanctions may be applied, which must be substantiated in all cases:

A) Observation.

B) Warning.

C) Fines of up to U.I. 1,000,000.

D) Suspension.

E) Dismissal.

Additionally, when the Disciplinary Process is applied due to an act or an omission by an employee of the Broker, the suspension may be for up to a maximum of 30 days, and, should Dismissal be appropriate, both sanctions may be accumulative.

Validity. Modifications.

These Regulations, as well as any subsequent modification to be carried out due to the existence of new regulations, legal or regulatory, or for reasons of mere opportunity or convenience, will require approval by the Board of Directors, whose minutes will be included as an Annex.