Stock Exchange Ethics Instruction

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The Board of Directors of the Stock Exchange of El Salvador, S.A. de C.V., exercising the powers granted to it by Article 29 of the Securities Market Law, through an agreement taken in a Board of Directors session JD-20/2021, dated November 23, 2021, agreed to authorize 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, promoting high standards of ethical and professional conduct in order to preserve the fairness, transparency, and security of the stock market and protect the interests of the 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 authorizations granted.

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 at the Stock Exchange.

DEFINITIONS
Art. 2.- For the purposes of this document, the following shall be understood:

a. Exchange, Stock Exchange or BVES: Stock Exchange of El Salvador, S.A. de C.V. b. Brokerage House: Member Brokerage House of the Stock Exchange of 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 is held.
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 be perceived to influence the professional judgment or decision of an entity member regarding the fulfillment of their obligations. f. Brokers: Stock brokers authorized to operate at the Stock Exchange of 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, without 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 the Brokers adhere their conduct to this Instruction, and may sanction, in accordance with it and the General Internal Regulations of the Exchange, those behaviors that violate this regulation.

It shall be 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 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 report it to the Disciplinary Committee, so that it takes the appropriate measures.

ETHICAL STANDARDS OF CONDUCT
Art. 4.- The ethical standards that the subjects mentioned in the previous article must comply with, in the development of their activities, will be based on:

a. Prioritizing the interests of clients or investors over the interest of the Exchange, the Brokerage House, any entity member of the financial conglomerate or business group, when there are conflicting interests. b. Equal treatment of clients, providing the same conditions and opportunities, avoiding any act, conduct, practice, or omission that could be detrimental to them.
c. Transparency and timeliness in the dissemination of information, and 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 could damage 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 social communication mechanisms facilitated by information and communication technologies.

GENERAL CONDUCT
Art. 5.- The obligated subjects, in carrying out their activities, are obliged 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 carrying out 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 compliance with applicable laws and regulations, as well as instructions, orders, and directives emanating from 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 houses must supervise that their brokers carry out their actions in accordance with the cited provisions.

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

OBLIGATION TO CONDUCT THEMSELVES INTEGRALLY Art. 7.- The obligated subjects must maintain a professional and integral conduct that allows for 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 INTERESTS
Art. 8.- In order to protect the interests of their clients, the officials of the Brokerage Houses and the 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 appropriate;
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 from the market or issuers 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 they entail; f. Prior to carrying out a transaction, they must inform the client of the charging policies for services 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 client 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 standards of conduct, related party transactions, 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 Standards of Conduct for Entities of the Stock Markets (NDMC-15), must establish mechanisms that allow preventing, identifying, managing, mitigating, reporting, and registering 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 of 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 Exchange or the Brokerage House, to the detriment of client interests;
c. Possibility of having financial, economic, or any other type of incentives to favor the interests of the Exchange, the Brokerage House, or third parties, over the interests of clients;
d. Possibility of receiving from a third party some incentive related to the service provided, different from 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 create a personal commitment or for the entity with which they are related, and that could detract from their objectivity in decision-making 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 could generate interference to illegitimately favor a client or group of clients to the detriment of other clients or the market.

The obligated subjects must immediately communicate to their hierarchical superior, to the Exchange, or to the Board of Directors, as appropriate, any situation that could result in a conflict of interest. Likewise, brokerage houses and the 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 Exchange to have a continuous process for the control, management, and recording of conflicts of interest in which everything considered as a conflict of interest event is documented clearly and impartially, the mechanisms to mitigate them, the procedure to follow in case of occurrence, and conflict resolution mechanisms when a conflict has arisen.

In the case of the Exchange, the provisions in the code of conduct policies manual and the Technical Standards of Conduct 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 what is mentioned in the previous paragraph and adhere to the aforementioned technical standards.

REGISTRATION OF CONFLICTS OF INTEREST
Art. 12.- The Exchange and the 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 Art. 12 of the Technical Standards of Conduct for Entities of the Stock Markets (NDMC-15).

TITLE II

PROHIBITION OF GIVING FALSE OR DISTORTED INFORMATION Art. 13.- The obligated subjects must refrain from giving false or distorted information; likewise, they are prohibited from spreading rumors or information or hiding information that distorts the price formation process or could affect decision-making by investors.

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

Likewise, the directors, officials, and employees of the Stock Exchange are obliged to keep in strict confidence all information they become aware of as a result of the activities inherent to their position or labor. They are also prohibited from using or revealing such information to obtain a benefit for themselves or third parties.

INSIDER INFORMATION
Art. 15.- Insider information shall be understood as any concrete information that refers directly or indirectly to one or more financial instruments, or to one or more issuers of said instruments, that has not been made public and that, if made or having been made public, could have influenced or would have influenced appreciably its quotation at the Stock Exchange; likewise, undisclosed relevant facts constitute insider information.

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

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

a. Carrying out, directly or indirectly, any type of transaction on their own account regarding securities, products, or financial transactions based on insider information, whether it belongs to the Exchange, the Brokerage House in which the official or employee may have some type of link, or to 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 transaction, whether acquiring or ceding securities, positions, or having others acquire or cede them, based on such insider information;
d. Carrying out or inducing third parties to carry out stock transactions through artifices that imply generating some type of expectation among investors, so that such inducement seeks to artificially manipulate buy and/or sell prices of securities traded or to be traded at the Exchange. In this sense, they must ensure that this does not occur through subordinates or trusted third parties.

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

a. Suggesting to issuers of securities to hide, manipulate, or not publish information that they are obligated to make known to the market, which could positively or negatively influence the results of buying and/or selling their titles registered at the Exchange; b. Carrying out transactions that cause an excessive rise or fall in a specific security and that can unjustifiably damage the interests of the issuing society itself, shareholders, or other Security Holders;
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 mechanisms for preventing market manipulation are regulated in the transaction monitoring section of the "Stock Exchange Operational Instruction."

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

PROHIBITION OF UNFAIR COMPETITION ACTS
Art. 18.- The officials and employees of the Brokerage Houses and the 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 according to applicable legislation; b. Guaranteeing returns to their clients that do not derive from the nature of the instruments or operations;
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 with respect to the rest of the participants, or that allow them to carry out transactions that place them in a position of advantage with respect to the rest of the 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 Exchange, the disciplinary sanctions to be applied.

When the alleged infringement is attributed to one of the directors of the Exchange, the alleged infringer cannot participate in the investigation and must be absent from the Board of Directors whenever the matter is discussed. The same procedure will be followed 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 Board of Directors of the Exchange, 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 Exchange; the Market and Operations Manager and the Legal Manager of the same. The Board of Directors of the Exchange may appoint substitutes. It is the responsibility of the General Manager to designate the person who will replace him.

POWERS OF THE DISCIPLINARY COMMITTEE
Art. 21.- It is the responsibility of the Disciplinary Committee to recommend to the Board of Directors of the Exchange the application of any of the sanctions provided for in the General Internal Regulations of the Exchange.

OF THE COMPLAINTS
Art. 22.- When the Exchange, within its supervisory powers, detects or receives a formal complaint about the existence of an infringement of this Instruction, it will communicate it immediately to the Disciplinary Committee, which will initiate the relevant investigation; for this purpose, it may be assisted by the Internal Audit Department of the Exchange, the Legal and Issuances Management, or any of the other Managements of the Exchange, who will be obliged to provide all the collaboration requested with the greatest speed.

Formal complaints must be submitted in writing to the General Management with an indication of the facts that motivated them, the subjects complained against, the place for 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 of the same which will contain a clear identification of the complainant, date, place, and time, as well as a description of the main facts that motivated it with an indication of 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 other identity document in which their signature appears. If the complaint is presented by a legal entity or on behalf of a natural person, in addition to what is indicated above, they must present that documentation that accredits their legal capacity to represent and the sufficient authority for that act. A copy of the referenced documentation must be attached to the complaint.

The presentation of the aforementioned documents will not be necessary when these or their copies are in the possession of the Exchange.

PROCEDURE
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