Breaches or compromise of this Code of Conduct are treated seriously
and may result in disciplinary action, as established by the Bank, from probation, deduction of wages,
demotion and/or reduction in pay, up to termination of employment, as the case maybe. Moreover, the Bank may
consider not adjusting salary for those under investigation or disciplinary actions being taken.
In 2025, there were 9 important cases of the Code of Conduct breaches, all of which were cases of misconduct (no cases of discrimination, harassment, violation of customer privacy data, conflicts of interest, money laundering, insider trading, corruption, or antitrust/anti-competitive practices). All of these cases had been managed. The Bank has enhanced its risk management process and reviewed its internal control and compliance to ensure higher efficiency and to prevent potential breaches. Key measures include improving significant work processes to be more prudent, monitoring the authentication process and power of attorney granted for financial transactions, as well as using technological capabilities and data analytics to detect behaviors that may constitute employee misconduct. Moreover, in cases of any Code of Conduct violations, the Bank will consider the cases and take action against those who fail to comply with the Code of Conduct, strictly and fairly in accordance with the established criteria, which may include written warning, deduction of wages or termination of employment, as the case may be.