The Board of Directors of Bolsa de Valores de El Salvador, S.A. de C.V., exercising the powers granted by Article 29 of the Securities Market Law, through an agreement taken in a Board of Directors meeting JD-20/2021, dated November 23, 2021, authorized this Stock Exchange Ethics Instruction, which was approved by the Standards Committee of the Central Reserve Bank of El Salvador, in Session No. CN-17/2021, dated December 20, 2021.

STOCK EXCHANGE ETHICS INSTRUCTION

TITLE I

OBJECTIVE

Art. 1.- This Instruction aims to establish the fundamental principles to which the conduct of officials and employees of Brokerage Houses, stock brokers, and the directors, officials, and employees of the Stock Exchange must adhere, hereinafter referred to as "the obligated subjects," in the stock market. It promotes high standards of ethical and professional conduct to preserve the fairness, transparency, and security of the stock market and protect the interests of the Stock Exchange's clients, the brokerage houses' clients, and the investing public.

The application of ethical principles and standards promotes the development of the securities market based on fair competition, the professionalism of its participants, and compliance with the applicable legal framework. Therefore, the actions of the obligated subjects must always adhere to regulated activities in accordance with the granted authorizations.

The scope of application of this instruction corresponds to the actions of the obligated subjects regarding their activities as participants in the securities market, and especially in the transactions carried out on the Stock Exchange.

DEFINITIONS

Art. 2.- For the purposes of this document, the following terms are understood as:

a. Stock Exchange, Stock Exchange or BVES: Bolsa de Valores de El Salvador, S.A. de C.V. b. Brokerage House: Member Brokerage House of Bolsa de Valores de El Salvador, S.A. de C.V.
c. Client: Those who have a legal relationship with the obligated subjects, the Brokerage Houses, or the Stock Exchange; provided that such legal relationship falls within the purpose or main business of the subject with whom the relationship exists.
d. Disciplinary Committee: Disciplinary Committee of the Stock Exchange. e. Conflict of Interest: Any situation in which a personal benefit or interest of a third party may influence the professional judgment or decision of a member of the entity regarding the fulfillment of their obligations. f. Brokers: Stock brokers authorized to operate on Bolsa de Valores de El Salvador, S.A. de C.V. g. Director: Member of the Board of Directors of the Stock Exchange. h. Official: The Directors, the President, the General Manager, and the Area Managers of the Stock Exchange and the Brokerage Houses.
i. Employee: Those who, not being officials, are linked to the Stock Exchange or the Brokerage Houses by an indefinite employment contract or temporary contract.
j. General Manager: General Manager of the Stock Exchange.

k. Manager: Whoever holds that position at the Stock Exchange or Brokerage Houses.
l. Board of Directors: The Board of Directors of the Stock Exchange.
m. President: President of the Stock Exchange. n. Investing Public or Investor: Anyone who invests in financial instruments that can be traded through the Stock Exchange; o. Superintendence: Superintendence of the Financial System.

SUPERVISION

Art. 3.- The Stock Exchange will supervise that the employees and officials of the Brokerage Houses and Brokers adhere their conduct to this Instruction, and may sanction, in accordance with the same and the Stock Exchange's general internal regulations, those behaviors that violate this regulation.

It is the responsibility of the Manager of each area to supervise that their subordinates adhere their conduct to this Instruction, the General Manager to supervise that the Area Managers do so, and the President of the Stock Exchange to supervise the conduct of the General Manager. Likewise, the Board of Directors will supervise the conduct of the President:

When any of the subjects mentioned in the previous paragraph becomes aware of an infringement of this Instruction by any of the persons under their supervision or by any other person, they must immediately report it to the Disciplinary Committee, so that it may take the appropriate measures.

ETHICAL STANDARDS OF CONDUCT

Art. 4.- The ethical standards that the subjects mentioned in the previous article must fulfill in the development of their activities will be based on:

a. Prioritizing the interests of clients or investors over the interests of the Stock Exchange, the Brokerage House, any entity member of the financial conglomerate or business group, when there are conflicting interests. b. Equal treatment to clients, providing the same conditions and opportunities, avoiding any act, conduct, practice, or omission that may be detrimental to them.
c. Transparency and timeliness in the dissemination of information, especially regarding the application of commissions, expenses, surcharges, and any other charges associated with the services provided.
d. Refraining from acting under the influence of any situation generating a conflict of interest or other circumstances that could alter the integrity of the service and/or product. e. Performing their activities with honesty and diligence, avoiding acts that may deteriorate the reputation of the entity they serve or the integrity of the markets. f. Refraining from using confidential or privileged information for their own benefit or that of third parties to the detriment of clients or the market. g. Maintaining at all times, during the exercise of their functions or activities as representatives, agents, or employees of the obligated subjects, conduct adhering to the ethical and professional standards developed in this Instruction, both in physical and virtual public spaces, social media publications, and any other type of communication mechanisms facilitated by information and communication technologies.

GENERAL CONDUCT

Art. 5.- The obligated subjects, in carrying out their activities, are obligated to conduct themselves with honesty, integrity, diligence, impartiality, probity, and good faith.

Likewise, they must generate conditions that increase the credibility of the stock market, and when performing activities in the market, they must ensure that the transactions in which they intervene are carried out in accordance with current regulations and sound market practices.

OBLIGATION TO COMPLY WITH REGULATIONS

Art. 6.- The obligated subjects must act in accordance with applicable laws and regulations, as well as instructions, orders, and directives issued by the Stock Exchange and other technical regulations issued by the Standards Committee of the Central Reserve Bank. Therefore, they must refrain from executing instructions that are contrary to such provisions; likewise, the brokerage houses must supervise that their brokers carry out their actions in accordance with the cited provisions.

Officials and employees of the Brokerage Houses and Brokers must report to the Stock Exchange, and if possible, provide evidence of violations of the regulations of which they have knowledge.

OBLIGATION TO BEHAVE INTEGRALLY

Art. 7.- The obligated subjects must maintain a professional and integral conduct that allows the transparent and orderly development of the market. Consequently, they are prohibited from:

a. Participating in activities that create false conditions of supply or demand that influence market prices or rates;

b. Altering prices or rates through deception or rumor;

c. Altering or interrupting without justified cause the normality of operations in the stock market;

d. Carrying out transactions that put at risk the capacity for fulfillment and settlement of the same;

e. Carrying out transactions without the express authorization of the client;

f. Using client resources for any purpose other than that authorized by the client or improperly combining client resources among clients.

PROTECTION OF CLIENT INTEREST

Art. 8.- In order to protect the interests of their clients, officials of the Brokerage Houses and Brokers must:

a. Identify the needs of their clients, so that the products and services they recommend are the most appropriate and aligned with their objectives;

b. Keep their clients duly informed of relevant facts about issuers and market issuances, as applicable;

c. Formulate recommendations to their clients that represent their well-founded opinion and based on information that is in the public domain;

d. When advising a client, market information or issuer information must be distinguished from the recommendation or opinion of the Brokerage House or broker, according to the corresponding service contract;

e. Ensure that their clients know the nature of the transactions they enter into and the risks involved;

f. Prior to carrying out a transaction, they must inform the client of the service charging policies and any eventual expenses generated by the transactions they enter into;

g. Not induce the client to carry out transactions solely to favor the Broker, the Brokerage House, or any entity member of the financial conglomerate or business group of which it is part;

h. Execute their clients' instructions in accordance with principles of equal treatment and timeliness, as well as under the best market conditions; and

i. Develop in the Code of Ethics or Code of Conduct the procedures, management, and controls for handling potential conflicts of interest, policies on ethical conduct standards, transactions with related parties, confidentiality, reserve, and use of privileged information.

IDENTIFICATION OF CONFLICTS OF INTEREST

Art. 9.- The obligated subjects, in accordance with what is stipulated in the Technical Conduct Standards for Entities of the Stock Markets (NDMC-15), must establish mechanisms that allow them to prevent, identify, manage, mitigate, inform, and register conflicts of interest that may exist in each operation, product, and line of business, taking into consideration incentive relationships, segregation of functions, and independence, identifying at minimum the following situations:

a. Existence of an interest in the result of the service provided to the client or a transaction carried out on behalf of the client, which differs from the client's interest in that result;

b. Possibility of obtaining a financial or economic benefit, or avoiding a loss to the Stock Exchange or the Brokerage House, to the detriment of clients' interests;

c. Possibility of having financial, economic, or any other type of incentives, to favor the interests of the Stock Exchange, the Brokerage House, or third parties, over the interests of clients;

d. Possibility of receiving from a third party any incentive related to the service provided, other than the usual commission or what is established in the provision of such services; and

e. Other situations that by their nature may be identified.

PROHIBITION OF ACTS THAT PRODUCE CONFLICTS OF INTEREST

Art. 10.- The obligated subjects must avoid conflicts of interest with their clients, among them, or with the entity they represent. Consequently, they are prohibited from:

a. Offering, giving, soliciting, or accepting incentives that originate a personal commitment or for the entity with which they are related, and that may deprive them of objectivity in decision-making regarding matters related to the person to whom the incentive was offered, given, solicited, or accepted;

b. Participating in any type of activities that are incompatible with their functions;

c. Using their position, authority, or the information they know in the exercise of their office, confidential or not, for the conduct of any kind of business; in the case of exercising teaching activities, they must keep the confidentiality of the information at all times;

d. Favoring the interests of one client to the detriment of another client or the market; and

e. Receiving gifts, invitations, or any benefit from clients that compromise the duty of impartiality or may generate interference to illegitimately favor one client or group of clients to the detriment of other clients or the market.

The obligated subjects must immediately communicate to their hierarchical superior, the Stock Exchange, or the Board of Directors, as applicable, any situation that could result in a conflict of interest. Likewise, the brokerage houses and the stock exchange must establish institutional mechanisms to prevent conflicts of interest from arising among their various areas.

MANAGEMENT OF CONFLICTS OF INTEREST

Art. 11.- It is the obligation of the Brokerage Houses and the Stock Exchange to have a continuous process for the control, management, and registration of conflicts of interest, in which everything considered as a conflict of interest event is clearly and impartially documented, the mechanisms to mitigate them, the procedure to follow in case of occurrence, and conflict resolution mechanisms when a conflict has been generated.

In the case of the Stock Exchange, the provisions of the conduct policies manual and the Technical Conduct Standards for Entities of the Stock Markets (NDMC-15) approved by the Standards Committee of the Central Reserve Bank will apply; the brokerage houses must design control mechanisms that at minimum consider the aforementioned in the previous paragraph and adhere to the technical regulations cited above.

REGISTRATION OF CONFLICTS OF INTEREST

Art. 12.- The Stock Exchange and the Brokerage Houses will keep an updated record, which may be centralized or decentralized, physical or digital, of the conflicts of interest that arise; which must comply with and present the information prescribed by Article 12 of the Technical Conduct Standards for Entities of the Stock Markets (NDMC-15).

TITLE II

PROHIBITION OF PROVIDING FALSE OR DISTORTED INFORMATION

Art. 13.- The obligated subjects must refrain from providing false or distorted information; likewise, they are prohibited from disseminating rumors or information or concealing information that distorts the price formation process or may affect decision-making by investors.

CONFIDENTIALITY OF INFORMATION

Art. 14.- Officials and employees of the Brokerage Houses and Brokers must keep confidential the information of their clients and the transactions they enter into in their accounts, as well as any information they know as a result of the activities inherent to their position or labor; however, they may provide such information only when required in writing by the Stock Exchange or a competent authority in the exercise of their functions. Likewise, they are prohibited from using such information to obtain a benefit for themselves, the entity they work for, or third parties.

Similarly, the directors, officials, and employees of the Stock Exchange are obligated to keep confidential all information they know as a result of the activities inherent to their position or labor. They are also prohibited from using such information or revealing it to obtain a benefit for themselves or third parties.

PRIVILEGED INFORMATION

Art. 15.- Privileged information is understood as any concrete information that refers directly or indirectly to one or more financial instruments, or to one or more issuers of the cited instruments, that has not been made public and that, if made or having been made public, could influence or would have influenced appreciably its quotation on the Stock Exchange; likewise, undisclosed relevant facts constitute privileged information.

The obligated subjects are prohibited from using, disclosing, and relying on the knowledge or possession of privileged information for their own benefit, their business group, conglomerate, or third parties, whether directly or indirectly, for themselves or third parties; they are also prohibited from trading or inducing third parties to trade securities or derivative products referred to securities, the price of which may be influenced by the privileged information they possess. Likewise, the brokerage houses and the stock exchange must establish institutional mechanisms to ensure that privileged information available to some of their areas cannot be used for their own benefit or that of third parties.

OBLIGATION TO SAFEGUARD INFORMATION

Art. 16.- Anyone who has access to privileged information must safeguard it under strict confidentiality and reserve so as to avoid the improper use of the same. For this reason, Brokers, officials, or personnel who have access to privileged information must refrain from the following:

a. Carrying out, directly or indirectly, any type of operation on their own account regarding securities, products, or financial transactions based on privileged information, whether it belongs to the Stock Exchange, the Brokerage House in which the official or employee may have some type of link, or any entity member of the financial conglomerate or business group;

b. Communicating it to third parties, except in the normal exercise of their work, profession, or position;

c. Recommending to third parties to carry out any type of financial operation, whether acquiring or transferring securities, positions, or having others acquire or transfer them, based on such privileged information;

d. Carrying out or inducing third parties to carry out stock market transactions through artifices that imply generating some type of expectation among investors, so that such induction seeks to artificially manipulate the purchase and/or sale prices of securities traded or to be traded on the Stock Exchange. In this sense, they must ensure that this does not occur through subordinates or trusted third parties.

MARKET MANIPULATION

Art. 17.- Market manipulation will be considered in accordance with the Securities Market Law, the provisions of the Technical Conduct Standards for Entities of the Stock Markets (NDMC-15), Article 13 of this Instruction, and the following activities:

a. Suggesting to securities issuers to conceal, manipulate, or not publish information that they are obligated to make known to the market, which may positively or negatively impact the results of buying and/or selling their titles registered on the Stock Exchange;

b. Carrying out transactions that cause an excessive rise or fall in a specific security and that may unjustly damage the interests of the issuing society itself, shareholders, or other holders of the securities;

c. The repeated request for change of guarantees in repo operations;

d. The cancellation of transactions and the carrying out of new ones with the same securities at different prices.

The market manipulation prevention mechanisms are regulated in the transaction monitoring section of the "Stock Exchange Operability Instruction."

In the event of the occurrence of the aforementioned, proceedings and sanctions will be applied, if applicable, in accordance with the provisions of the sanctions section of this document and what is applicable in the General Internal Regulations.

PROHIBITION OF UNFAIR COMPETITION ACTS

Art. 18.- Officials and employees of the Brokerage Houses and Brokers must refrain from carrying out any type of unfair competition acts. Consequently, they are prohibited from:

a. Offering products, services, or combinations of both based on anti-competitive practices in accordance with applicable legislation;

b. Guaranteeing returns to their clients that do not derive from the nature of the instruments or transactions;

c. Disseminating incorrect or exaggerated data to the investing public about their performance; and

d. Using fraudulent, unethical, deceptive, or illegitimate means to place themselves in a position of advantage relative to other participants, or to allow them to carry out transactions that place them in a position of advantage relative to other participants.

TITLE III

DISCIPLINARY COMMITTEE

Art. 19.- The Disciplinary Committee is the collegiate body responsible for analyzing and evaluating information that evidences alleged infringements of this Instruction, committed by the obligated subjects of the stock system. In order to establish the degrees of responsibility of each of the parties and on that basis, recommend to the Board of Directors of the Stock Exchange, the disciplinary sanctions to be applied.

When the alleged infringement is attributed to one of the Stock Exchange's directors, the alleged infringer may not participate in the investigation and must be absent from the Board of Directors whenever the matter is discussed. The same procedure will apply when the alleged infringer is part of the Disciplinary Committee.

COMPOSITION OF THE COMMITTEE

Art. 20.- The Disciplinary Committee is composed of at least one member of the Stock Exchange's Board of Directors, who does not represent any of the Brokerage Houses nor belongs to the financial conglomerate or business group of the same; the General Manager of the Stock Exchange; the Market and Operations Manager and the Legal Manager of the same. The Stock Exchange's Board of Directors may appoint alternates. It is the responsibility of the General Manager to designate the person who will substitute them.

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POWERS OF THE DISCIPLINARY COMMITTEE

Art. 21.- It is the responsibility of the Disciplinary Committee to recommend to the Stock Exchange's Board of Directors the application of any of the sanctions provided for in the Stock Exchange's General Internal Regulations.

ON COMPLAINTS

Art. 22.- When the Stock Exchange, within its supervisory powers, discovers or receives a formal complaint regarding the existence of an infringement of this Instruction, it will immediately communicate it to the Disciplinary Committee, which will initiate the relevant investigation. For this purpose, it may be assisted by the Stock Exchange's Internal Audit Department, the Legal and Issuances Management, or any of the other Stock Exchange Managements, who will be obligated to provide all the cooperation requested as soon as possible.

Formal complaints must be submitted in writing to the General Management with an indication of the facts motivating them, the accused subjects, place of notifications, and a clear identification of the complainant, whose signature must appear in the document duly authenticated.

In the event that the complaint is presented verbally, the Internal Audit department will draw up an act thereof, which shall contain a clear identification of the complainant, date, place, and time, as well as a statement of the main facts motivating it, indicating the place to receive notifications. If the complaint is presented by a natural person, it must be signed by them, prior to presentation of their unique identity document, passport, or any identity document in which their signature appears. If the complaint is presented by a juridical person or on behalf of a natural person, in addition to the above, they must present documentation accrediting their legal capacity to represent and sufficient authority for that act. A copy of the aforementioned documentation must be attached to the complaint.

It will not be necessary to present the aforementioned documents when these or their copies are in the possession of the Stock Exchange.

PROCEDURE

Art. 23.- Upon completion of the investigation referred to in the preceding article, the Disciplinary Committee will submit a written report to the Board of Directors detailing the investigation conducted and its results, the appropriateness or not of imposing sanctions, in the Committee's judgment, and the reasoned recommendation of the sanction to be imposed, where applicable.

The Board of Directors will analyze the Committee's report, which is not binding, and will agree on whether or not to initiate the respective sanctioning procedure, in accordance with the General Internal Regulations.

EVALUATION CRITERIA

Art. 24.- The Disciplinary Committee, when submitting the report and recommending the type of sanction to be applied, must take into account the criteria defined in the General Internal Regulations.

SANCTIONS

Art. 25.- It corresponds exclusively to the Board of Directors of the Stock Exchange to adjudicate violations of this Instruction.

The Board of Directors of the Stock Exchange, after consideration and analysis of the recommendation made by the Disciplinary Committee and following the respective procedure, may impose any of the sanctions established in the General Internal Regulations of the Stock Exchange.

OTHER PROVISIONS
Art. 26.- The Disciplinary Committee must maintain strict confidentiality regarding the cases it handles, except in those cases where, in compliance with other regulatory bodies or a request from the relevant judicial or administrative instance, it is obligated to provide information.

Any situation they consider contrary to its purpose and responsibility must be immediately notified to the President of the Board of Directors of the Stock Exchange.

REPEAL
With the entry into force of this Instruction, the Stock Exchange Ethics Instruction approved by the Board of Directors of the Stock Exchange of El Salvador, through agreement No. JD-09/2011 dated June 28, 2011, and authorized by the Securities Superintendence through resolution No. RSTE-1/2011 dated July 29, 2011, is hereby repealed.

VALIDITY
This Instruction will enter into force fifteen business days after its approval by the Standards Committee of the Central Reserve Bank of El Salvador.

José Valentín Arrieta Whisohant
General Manager