Agreement No. 9 (2025) Updating the Administrative Procedure for Handling Complaints Before the Superintendence of Banks

Republic of Panama Superintendence of Banks of Panama AGREEMENT No. 9-2025 (November 12, 2025) Updating the administrative procedure for handling complaints before the Superintendence of Banks THE BOARD OF DIRECTORS in the exercise of its legal powers, and CONSIDERING: That following the issuance of Law Decree No. 2 of February 22, 2008, the Executive Branch prepared a systematic ordering in the form of a single text of Law Decree No. 9 of February 26, 1998, and all its modifications, which was approved through Executive Decree No. 52 of April 30, 2008, hereinafter the Banking Law; That in accordance with item 4 of Article 5 of the Banking Law, it is an objective of the Superintendence of Banks to ensure legal balance between the banking system and its clients; That in accordance with item 5 of Article 11 of the Banking Law, it is an attribute of a technical nature of the Board of Directors to fix, within the administrative scope, the interpretation and scope of legal or regulatory provisions in banking matters; That in accordance with Article 198 of the Banking Law, the Superintendence of Banks is granted exclusive competence to hear and protect the rights of the banking consumer, in accordance with the conditions established in Article 199 of the aforementioned norm; That in accordance with Articles 208 and 211 of the Banking Law, the Superintendence of Banks will have exclusive competence to hear and decide in the administrative channel the complaints that, due to violation of the norms established in Titles V and VI of the Law, are filed by banking consumers against banks up to an amount of twenty thousand balboas (B/. 20,000.00), when the bank fails to resolve the consumer's complaint within thirty (30) days and, when the decision on the complaint by the bank, even if timely, does not satisfy the banking consumer; That through Agreement No. 5-2025 of July 15, 2025, the amounts established in Article 199 of the Banking Law are updated, which are taken into consideration for the determination of a client as a banking consumer, as well as the maximum amount to hear and decide the complaints filed before this Superintendence, in accordance with Article 208 of the Banking Law; That Agreement No. 3-2008 of July 24, 2008, establishes the procedure for the handling of complaints before the Superintendence applied to general license banks in accordance with what is established in Chapter IV of Title VI of the Banking Law;

Agreement No. 9-2025 Page 2 of 8 That through Agreement No. 8-2020 of July 16, 2020, Articles 8 and 13 of Agreement No. 3-2008 are modified, in order to establish the use of email as a means to notify the parties of the resolution that admits and decides the complaint and to streamline the processes for the handling of complaints before the Superintendence of Banks; That with the objective of contributing to environmental sustainability, the Superintendence of Banks of Panama, as part of its management, has implemented various actions internally within the institution, aimed at reducing the impact of paper printing on the environment, supported by the use of digital tools and electronic signature; That in working sessions of this Board of Directors, the need and convenience of updating the provisions related to the complaint handling procedure before the Superintendence of Banks have been highlighted, in order to facilitate and streamline its processes through digital mechanisms and reduce paper use. AGREES: ARTICLE 1. SCOPE OF APPLICATION. This Agreement shall apply to banking consumers and general license banks in accordance with what is established in the Chapter IV of Title VI of the Banking Law. ARTICLE 2. COMPETENCE. The Superintendence of Banks will hear complaints from banking consumers against banks, in the following cases:

1. When having received a response from the bank within the term of thirty (30) days subsequent to the filing of the complaint, and the banking consumer is unsatisfied with it. In this case, the banking consumer will have a term of up to thirty (30) calendar days, counted from the date on which they obtained formal response from the bank, to file their complaint before the Superintendence of Banks.
2. When the bank does not respond to the banking consumer within the term of thirty (30) days subsequent to the filing of the complaint, established in the Banking Law. Upon expiration of this term, the consumer will have a term of up to thirty (30) calendar days to file their complaint through the administrative channel before the Superintendence of Banks. ARTICLE 3. REPRESENTATION. Banking consumers may act before the Superintendence of Banks:
3. By themselves.
4. Represented by a third party who may or may not be a lawyer. In the case that the action is through representation by a third party, as indicated in item 2, the power of attorney presented must comply with legal formalities and requirements. No obstant, when the banking consumer is a legal entity, it may act through its legal representative, accrediting such condition through a certificate issued by the Public Registry, which may not be older than six (6) months. , as defined below, shall be understood to be carried out by persons duly authorized by the bank. Likewise, the representatives of the parties participating in hearing acts or meetings ordered by this Superintendence must be duly empowered to receive, withdraw, substitute, submit, commit, settle, or celebrate agreements and, therefore, their actions will be binding on their represented parties. ARTICLE 4. ELECTRONIC FILE. The Superintendence of Banks will implement the use of technological and computer tools that it determines, hereinafter the

Agreement No. 9-2025 Page 3 of 8 general license banks in the administrative channel. Every complaint filed will give rise to the formation of an electronic file on the Platform, to which banking consumers, banks or their accredited representatives, as applicable, will have access. For these purposes, banking consumers or their duly accredited representatives must register through the Platform, in order to obtain an access key or credential that allows them to file the complaint and carry out their actions and management within the electronic files of complaints. On its part, the Superintendence of Banks will deliver to each bank through its authorized representative, a key or credential that allows them to enter the Platform, to carry out their actions and management within the electronic files of complaints. The authorized representative will be designated as the key administrator, which will allow them to create different users who may have access to the Platform to carry out the corresponding management. Likewise, the authorized representative will be responsible for the elimination of such users from the system, when their employment relationship with the banking entity ceases. In the event that the bank effects a change of the initially authorized representative, it must notify it through its legal representative or attorney duly empowered for this type of designation. ARTICLE 5. FILING OF THE COMPLAINT. The complaint shall be filed before the Superintendence of Banks electronically, through the Platform, and must contain the following information:

1. General information of the banking consumer. (ID number or passport, nationality, phone number of residence, office, mobile, residential and work address).
2. Email address for notification purposes.
3. Identification of the bank against which the complaint is filed.
4. The facts supporting the complaint, what is demanded from the bank, and the amount or value claimed, where applicable.
5. The proof of filing of the complaint issued by the Bank's Complaint Handling System and a copy of the formal response given by the bank, if any.
6. The evidence supporting the complaint, or to adduce it.
7. Document or proof accrediting the contractual relationship, that is, the type of product or service and the initial amount or limit thereof, in accordance with the parameters established in Article 199 of the Banking Law.
8. When the banking consumer is a legal entity, it must present a certificate issued by the Public Registry, where its validity and representation are recorded, which may not be older than six (6) months. PARAGRAPH 1. The Superintendence of Banks may request any other document or requirement it deems necessary for the clarification of the facts in the complaint process. PARAGRAPH 2. When the complaint is made in person, it will be incorporated into an electronic file, so that, henceforth, it continues its processing electronically. Notwithstanding, the consumer may know the status of their claim by appearing personally at the offices of the Superintendence of Banks. PARAGRAPH 3. In the event that the banking consumer has not previously filed the complaint before the bank, the Superintendence of Banks will request them to comply with this first stage.

Agreement No. 9-2025 Page 4 of 8 ARTICLE 6. ACCESS TO FILES. In attention to banking confidentiality, only the parties and their accepted attorneys within the complaint process will have access to the complaint file. ARTICLE 7. ADMISSION, CORRECTION, REJECTION, INHIBITION OR DECLINATION OF THE COMPLAINT. The Superintendence of Banks will have a term of five (5) business days to admit, order its correction, reject, inhibit itself or decline the complaint, counted from the next business day following its filing. Once the complaint is filed, the Superintendence will review the substantiation of the facts and the documentation; if everything is in due form, it will admit the complaint. If the complaint lacks or omits any of the formalities established in the Law or in this Agreement, its correction will be ordered, which must be carried out within two (2) business days following its notification. The complaint filed by a person who does not fall under the concept of banking consumer, as defined in the Banking Law, or whose claims exceed the limits established in the Law, will be rejected through a reasoned resolution, in which the archiving of the file will be ordered. In the event that this Superintendence is not competent to hear the complaint, it will abstain from hearing it and will proceed to inhibit itself and decline it to the competent authority. Once the complaint is admitted, this fact will be notified to the parties, their representatives or attorneys. ARTICLE 8. TRANSFER AND ANSWER. The Superintendence of Banks will give transfer of the complaint to the bank electronically, via email, for it to answer within a term of five (5) business days, counted from the day following its notification in accordance with what is established in item 2 of Article 14 of this Agreement. With its answer, the bank must attach the following:

1. Complete copy of the procedure or management carried out regarding the complaint in its Complaint Handling System, including all the substantiations that motivated the response provided to the banking consumer.
2. The contracts, addendums, or any other document accepted and/or signed by the banking consumer where the terms and conditions applicable to the product or service banking on which the complaint revolves are recorded, and that substantiate the contractual relationship with the banking consumer.
3. The evidence supporting the answer to the complaint or to adduce it.
4. Any other requirement determined by the Superintendence of Banks. ARTICLE 9. ORAL PROCEDURE (HEARING). Once the term for transfer has expired, the Superintendence of Banks, within the next five (5) business days, will set the date for the celebration of a hearing act with the parties, in person or virtual, in accordance with the rules and in the cases detailed below:
5. The following complaints will apply to processing through hearing, as single-instance processes: a. Claims whose value does not exceed one thousand five hundred balboas (B/.1,500.00). b. Claims whose object is to achieve the recognition of rights linked to the provisions contemplated in Agreement No. 1-2011 on transparency of information by the use of banking products and services and in Agreement No. 4-2011 on the charging of certain commissions and surcharges by banking entities.

Agreement No. 9-2025 Page 5 of 8 2. The hearing will be held on the day and hour indicated, which must be notified with an advance of no less than five (5) business days, and will be held with the intervention of the parties that attend. In case that none of the parties attend the hearing, the Superintendence of Banks will proceed in accordance with what is indicated in item 5 of this article. 3. Once the hearing has begun, a brief summary of the complaint and its answer will be made, then the floor will be given to the claimant and subsequently to the bank, for a period of up to thirty (30) minutes each. 4. The parties may provide evidence in the hearing act as long as it is closely related to the facts. In the hearing act, the Superintendence of Banks may order the practice of any evidence it deems relevant or appropriate to verify the assertions of the parties and the authenticity and accuracy of any public or private document provided to the process. 5. If the file contains sufficient evidentiary elements, the Superintendence of Banks will proceed to issue, in the act, the final Resolution that decides the complaint or may resort to the term of ten (10) business days to do so. 6. If the practice of any evidence adduced by the parties is required, an additional term of no more than ten (10) business days will be granted. PARAGRAPH. Complaints related to banking services provided through electronic means or channels are exempt from this procedure. ARTICLE 10. ORDINARY PROCEDURE. In those cases where the oral process does not apply, once the term to present the answer to the complaint by the bank has ended, and at any time before issuing the decision on the complaint, the Superintendence of Banks, if it deems it necessary, may order by provision the celebration of a meeting with the parties in person or virtual. This provision will be notified with an advance of no less than five (5) business days. In the event that the parties reach an agreement during the aforementioned meeting, the agreement between parties will be approved by resolution and the closure and archiving of the process will be ordered. When one of the parties has adduced evidence in their complaint or answer, the Superintendence will admit and order the practice of those evidence that are relevant or appropriate. The term for the practice of evidence may not exceed twenty-one (21) business days. The resolution of the Superintendence of Banks in these cases is unappealable. ARTICLE 11. OFFICIAL EVIDENCE. Before issuing the decision on the complaint, both in the oral process and in the ordinary procedure, the Superintendence of Banks may practice official evidence and among these:

1. Conduct a special remote or on-site inspection, of the bank's systems and files of the banking consumer that are held at the bank, and that relate to the complaint filed, through the technical areas of the Superintendence of Banks.
2. Order the official practice of any other evidence it deems relevant or appropriate to verify the assertions of the parties and the authenticity and accuracy of any public or private document in the process. The resolution of the Superintendence of Banks in these cases is unappealable and in it the term for the practice of evidence will be indicated, which may not exceed twenty-one (21) days business.

Agreement No. 9-2025 Page 6 of 8 ARTICLE 12. ARGUMENTS. Upon conclusion of the meeting with the parties or the conclusion of the evidentiary stage, the consumer and the bank will have a common period of two (2) business days to present their arguments. ARTICLE 13. DECISION ON THE COMPLAINT. Once the procedural stages comprised in the Oral Procedure or the Ordinary Procedure have concluded, the Superintendence of Banks through a reasoned resolution, will issue the decision that resolves the complaint. In the oral procedure, the decision resolving the complaint may be issued in the hearing act itself or within a term no greater than ten (10) business days counted from the hearing. In the ordinary procedure, the decision resolving the complaint will be issued within a term no greater than one hundred twenty (120) calendar days, counted from the conclusion of the argument stage. The resolution of the Superintendence of Banks will have a binding character for both parties and must be complied with within a term of five (5) business days counted from the finality of the resolution, unless a different term is indicated in it. The Superintendence of Banks, in the face of repeated complaints if it deems it necessary, may require the bank to present an action plan that allows addressing and correcting the problems or deficiencies detected as the object of the complaint filed. ARTICLE 14. NOTIFICATIONS. Notifications to the parties will be made simultaneously through the following means:

1. Through notices posted on the Platform on which the electronic files are processed, in which case the notification will be considered served when two (2) business days have elapsed following its publication, and,
2. Via email, to the email indicated by the parties, in which case the notification will be understood as made after two (2) business days have elapsed following the sending of the email. The Resolution that admits and the one that resolves the complaint, will be notified via email. In the event that the email provided by any of the parties presents sending errors preventing the receipt of the email with the notification, an edict will be posted through the institution's website in the section of edicts on the customer service portal. ARTICLE 15. APPEALS. The resolutions adopted by the Superintendent will admit appeals for reconsideration and appeal in accordance with the following parameters:
3. Only Admit Appeal for Reconsideration: a. The resolution that rejects the complaint. b. The resolution that decides the Oral Process. c. The resolution that does not admit an appeal.
4. Only Admit Appeal for Appeal before the Board of Directors: a. The resolution that decides the Ordinary Process. b. The resolution that imposes sanctions for contempt for amounts greater than five thousand balboas (B/.5,000.00). PARAGRAPH. The appeals must be announced and substantiated, within five (5) business days following the notification and will be granted with suspensive effect. ARTICLE 16. TERMINATION OF THE PROCESS. The claim will be considered concluded and the archiving of the file will be ordered if any of the following circumstances occur:

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1. The withdrawal of the claimant or the submission of the bank at any stage of the complaint process.
2. The agreement or settlement between the parties, at any stage of the complaint process.
3. That the complaint is decided through a reasoned resolution. ARTICLE 17. TRANSGRESSIONS OF BANKING REGULATIONS. If during the course of the complaint process, the Superintendence of Banks estimates that the bank has infringed provisions of the Banking Law, or regulatory norms, it will proceed to formulate the corresponding charges. For this process, an administrative file will be opened, independent of the complaint. This procedure will not exempt the bank from the obligation to comply with the decision of the Superintendence with respect to the complaint. ARTICLE 18. CONTEMPT. The Superintendence of Banks may sanction the bank that ignores or fails to comply with any order issued within the complaint process, with a fine of one hundred balboas (B/.100.00) daily (calendar days) for as long as its refusal lasts. This is without prejudice to the consumer's right to demand compliance with the resolution deciding the complaint in the judicial sphere. An evasive or incomplete answer, the non-appearance of a bank representative at the hearings, meetings, and the non-compliance with the complaint decision within the term established for it, will be considered contempt, for the effects of this Agreement. The sanction will be imposed at the moment of deciding the complaint. ARTICLE 19. USE OF THE PLATFORM. The following provisions will be applicable to the use of the Platform and to the electronic complaint files:
4. Access to the platform will be available to the parties 24 hours a day. No obstant, every writing, document, appeal, or management must be presented in the same within the Superintendence of Banks' service hours. If presented outside this hours, it will be understood as presented on the next business day. When a term is running in the processes, it will be understood as timely fulfilled if the action is carried out within the term and in the service hours of the Superintendence of Banks, otherwise it will be understood as untimely.
5. When exceptionally there is an interruption of the Platform, either when the term is running or when the last day of the term to present an electronic document is passing, the term will be extended until the next business day on which it expires.
6. The bank and the banking consumer will be responsible for adopting appropriate security measures for the custody and use of the access keys or credentials that allow them to manage through the Platform.
7. The resolutions, certifications, notes, reports, and other diligences issued by the Superintendence of Banks in the complaint processes will be signed by qualified electronic signature.
8. The parties to the process are responsible for the quality, accuracy, authenticity, integrity, and reliability of the information or documentation they send or present through the Platform.
9. All documentation must be legible, reproducible, or consultable.

Agreement No. 9-2025 Page 8 of 8 ARTICLE 20. VALIDITY. This Agreement will begin to govern from November 15, 2026. Notwithstanding, the ongoing processes initiated before the entry into force of this Agreement will be subject to the provisions of Agreement No. 3-2008 and all its modifications. Given in the city of Panama, on the twelfth (12) day of the month of November of two thousand twenty-five (2025). NOTIFY, PUBLISH, AND COMPLY. THE PRESIDENT, THE SECRETARY, Adriana Raquel Carles Felipe Echandi Lacayo