Petitions, Complaints, Claims and Suggestions:

What is the SAC? It is the Consumer Service System and it is aimed at ensuring the protection the financial consumer vis-à-vis the institutions supervised by the Financial Superintendence.

What should we know about the SAC? The guiding principles that rule the relations between financial consumers and the controlled institutions are as follows:

Due Diligence: The controlled institutions under supervision of the Financial Superintendence of Colombia must apply due diligence when offering their products or delivering their services to the consumers, so that the latter receive relevant information and / or adequate and respectful attention in the development of their relations with those institutions and, in general, when carrying out their normal activities and operations. In that respect, relations between the controlled institutions and the financial consumers must be developed in a way that ensures that the needs of the financial consumer are met, in keeping with the offer, commitment and obligations previously agreed upon. The controlled institutions must follow the instructions by the Financial Superintendence of Colombia regarding the safety and quality of the different channels for financial services’ distribution.

Freedom of choice: Notwithstanding the special provisions imposed by the duty to supply a specific financial product or service, the controlled institutions and the financial consumers may freely choose their counterparties when entering into the contracts to establish the supply of goods or the rendering of services offered by the former. In case they refuse to render the services or offer the products, their refusal must be based on objective causes and it cannot be the result of a different and unjustified treatment to the financial consumers.

Transparency and true, sufficient and timely information: The supervised entities must supply the financial consumer true, adequate, sufficient, clear and timely information that specifically enables the financial consumers to properly know their rights, obligations and costs in the relations that are established with the controlled institutions.

Responsibilities of the controlled institutions when handling complaints: The controlled institutions must duly and efficiently handle the complaints or claims filed by financial consumers in compliance with the terms and conditions provided for in current regulation. Furthermore, after identifying the causes of the complaints and claims, they must design and implement the necessary, timely and continuous improvement actions.

Pursuant to what is set forth in the 7th Article of Law 1328 of 2009, the controlled institutions will have the following special obligations:

a) Giving information to the public with respect to the financial consumers’ advocate, in keeping with the Financial Superintendence of Colombia’s guidelines on the matter.

b) Duly delivering the product or providing the service, meaning under the conditions informed, offered or agreed with the financial consumer, and applying adequate safety and quality standards when delivering such products or providing such services.

c) Furnishing understandable information and transparent, clear, trustworthy and timely advertising about the products and services that they offer in the market.

d) Relying on a Financial Consumer Service System (SAC) as set forth herein, as well as in the decrees that regulate it and in the instructions by the Financial Superintendence of Colombia in this respect.

e) Refraining from incurring in behaviors that imply contractual abuses or agreeing to clauses that could affect the balance of the contract or give rise to an abuse of the dominant contractual position.

f) Drafting contracts and appendixes that clearly regulate customer relations (in characters that are legible in plain sight) and putting such documents at the clients’ disposal for their acceptance. A copy of the documents supporting the contractual relation must be at the disposal of the corresponding client and shall contain the terms and conditions of the product or service, the rights and obligations, as well as the interest rates, prices or fees and the way to determine them.

g) Refraining from making collections that have not been agreed upon or that have not been informed in advance to the financial consumer, in keeping with the terms set forth in the guidelines and regulations governing this matter, as well as putting at the disposal of the financial consumer the payment vouchers or support documents, transactions or operations carried out by any channel offered by the controlled institution. The conservation of such vouchers and supporting evidence must comply with standards on the matter.

h) Refraining from making any collections as related to pre – judicial collection expenses without having taken the steps and carried out the activities required for that purpose and without having previously informed the financial consumer of their value. Collection proceedings must be carried out respectfully and in the adequate times.

i) Maintaining the secrecy and confidentiality of any confidential information furnished by the financial consumer in the terms set forth in the applicable standards, notwithstanding the obligation to provide it to the competent authorities.

j) Giving evidence of the status and / or specific conditions of the products on a specific date when the financial consumer so requests it, in keeping with the procedure set forth for that purpose, except in cases where the controlled institution is in the obligation to do so without the need for previous request.

k) Addressing and giving a timely answer or solution to the requests, complaints or claims filed by financial consumers, following the procedures set forth for this purpose, the provisions set forth herein and in any other standards and regulations that may be deemed applicable.

l) Providing the necessary human, physical and technological resources so that the branches and agencies are capable to offer efficient and timely services to financial consumers.

m) Enabling its clients a free consultation, at least once a month, through the channels established by the institution, to check the status of their products and services.

n) Including in its Web site a link to the site of the Financial Superintendence of Colombia regarding financial consumers.

o) Reporting to the Financial Superintendence of Colombia (as the latter may determine) the price of all massively offered products and services. This information must be permanently disseminated by each controlled institution in its offices, its ATM networks and its Web page.

p) Informing financial consumers the cost of all transactions, if any, offering them the possibility to carry it out or not (in the terms set forth by the Financial Superintendence of Colombia, through the corresponding channel and prior to carrying out the operation.)

q) Possessing the electronic means and adequate controls to offer efficient transaction safety regarding the financial consumers’ confidential information and the networks that contain it.

r) Timely and diligently collaborating with the Financial Consumer Advocate, the judicial and administrative authorities, as well as the self – regulating organizations, in order to compile the information and obtain the evidence (if required), included those related to fraud, theft or any other behavior that can be considered a punishable offense perpetrated through the use of credit or debit cards, electronic or telephone transactions, or any other modality.

s) Refraining from requesting information to the financial consumer that is already in the hands of the controlled entity or any of its departments, branches or agencies, notwithstanding the financial consumer’s obligation to update the information as required by the pertinent standards or regulations.

t) Developing financial education programs and campaigns for its clients on the different products and services that they provide, their obligations and rights, the cost of the products and services that they offer, the markets and the type of controlled institutions, as well as the different mechanisms set forth for the protection of their rights, according to the Financial Superintendence of Colombia’s instructions in that respect.

u) All other dispositions set forth herein an in related standards, supplementary and regulatory standards, any standards as may be derived from the nature of the contract that has been entered into or the service that has been provided to the financial consumers, as well as the instructions issued by the Financial Superintendence of Colombia to comply with its functions and the rules of self – regulating organizations.”

Law 1328 of 2009 -specifically in its 5th Article- sets forth the rights of the financial consumers as follows:

a) Based on the principle of due diligence, the financial consumers must have the right to receive from the controlled institutions products and services that meet the safety and quality standards in compliance with the offered conditions and assumed obligations by the controlled institutions.

b) Access to transparent, clear, trustworthy, timely and verifiable advertising and information (in the terms set forth herein and in other special provisions) on the inherent characteristics of the products or services that are offered and / or supplied. Specifically, the information furnished by the corresponding institution must enable and facilitate comparisons and understanding regarding the different products and services offered in the market.

c) Demanding due diligence in the service provided by the controlled institutions.

d) Receiving adequate information on the different modalities to orchestrate the management of the offered products and services, along with their rights and obligations, the costs that will be generated from those products and services, the markets and activity types carried out by the controlled institutions, as well as the different protection mechanisms that have been established to defend their rights.

e) Respectfully present all the inquiries, petitions, requests, complaints or claims before the controlled institution, the Financial Consumer Advocate, the Financial Superintendence of Colombia and the self – regulating organizations.

f) The remaining rights as set forth in this law or in any other provisions, as well as those contained in the instructions given by the Financial Superintendence of Colombia.” This same Law -in its 6th Article- sets forth the self – protection practices for financial consumers themselves, which may be considered duties for them to consider, as follows:

1. Confirming if the entity with which they wish to enter into a contract or whose products or services they wish to obtain is duly authorized and supervised by the Financial Superintendence of Colombia.

2. Procuring information on the products or services that intend to acquire or use, inquiring about the general operating conditions; in other words, the rights, obligations, costs, exclusions and restrictions applicable to the product or service, while at the same time demanding the necessary, precise and sufficient verbal and written explanations that enable them to make informed decisions.

3. Abiding by the instructions and recommendations issued by the controlled institution regarding the handling of the financial products or services.

4. Reviewing the terms and conditions of the pertinent contract and its appendixes, as well as keeping the copies that they receive of those documents.

5. Procuring information on the agencies and means the institution counts on for the submission of petitions, requests, claims or complaints.

6. Obtaining a timely response to each request for a product or service.

1st PARAGRAPH. The non-exercise of the financial consumers’ self-protection practices does not imply the loss or disregard of their inherent rights when dealing with the controlled institutions and the competent authorities. Likewise, it does not exempt the controlled institutions from the special obligations that are provided for herein with respect to the financial consumers.

2nd PARAGRAPH. The financial consumers will have the duty to provide true, adequate, sufficient and timely information to the controlled institutions and to the competent authorities in cases when the latter demand such information to duly comply with their duties and update any data that requires it. Likewise, they will inform the Financial Superintendence of Colombia and other competent authorities about institutions that deliver financial products or provide financial services without being legally authorized to do so.”