Code of Integrity, Transparency, and Ethical Conduct

Specific objectives

• Identify fraud risks by conducting periodic operational monitoring and evaluating materialized events.
• Implement and maintain robust internal controls that minimize fraud opportunities.
• Build awareness among all employees regarding anti-fraud policies, associated risks, and preventive measures.
• Develop clear procedures for investigating fraud incidents and taking corrective action.
• Cooperate with competent authorities or regulatory bodies in investigation proceedings related to reported acts of fraud.
• Exchange best practices in fraud prevention with other entities in the sector.

The implementation of these guidelines will contribute to creating a safer and more transparent financial environment, where fraud risks are detected and mitigated effectively. Through a comprehensive approach combining monitoring, robust internal controls, ongoing training, clear investigation procedures, cooperation with authorities, and the exchange of best practices, the protection of consumer assets and public trust in the financial system will be ensured.

As members of the Board of Directors, Senior Management, Employees, and Suppliers of the Fondo Nacional del Ahorro S.A., we have the duty and responsibility to report in good faith any actual or apparent violation of this Code, carried out by employees, directors, or third parties contracted by the Company.

At the Fondo Nacional del Ahorro S. A., we are committed to creating a work environment in which every person feels free to report. Reports made through the Denuncie Seguro application, the Complaints Mailbox, corporate email, and external designated channels are distinct from those available for financial consumer complaints arising from the provision of services or products; accordingly, complaints or reports may be submitted anonymously or non-anonymously.

Enabled Reporting Channels

• Website application: Denuncie Seguro
• For employees: Intranet Denuncie Seguro
• Buzón de Denuncias: Nationwide: 018000112669. In Bogotá: (+57) (1) 4201686
• Email: [email protected]

Failure to comply with the duties, principles, and guidelines established in this Code of Integrity by any employee, director, public official, or contractor of the Fondo Nacional del Ahorro S. A. shall give rise to the application of corresponding sanctions, according to the severity of the infraction and in accordance with due process. The disciplinary measures provided for in the Código General Disciplinario, the Reglamento Interno de Trabajo, the Código Sustantivo del Trabajo, the Estatuto Orgánico del Sistema Financiero, and other applicable regulations shall be applied, without prejudice to any applicable administrative, civil, or criminal liability. The Company guarantees the right to a defense and due process at all stages.

Any breach of the Code by employees, directors, or contractors, whether intentional or negligent, may be sanctioned by the competent authority in accordance with applicable regulations.