This activity consists of performing Administration Agent and Attorney roles for all the investments made by Foreign Portfolio Investors in Colombia.

S3 CACEIS Colombia, as a Custodian of securities, will comply with the rules governing the Custody activity and the activities mandated to the Attorneys of IPEs in Colombia. To this end, S3 CACEIS Colombia will carry out any activities related to:

• Administration and legal representation of the IPEs in Colombia
• Safekeeping of the assets acquired by the IPEs in the Colombian public securities market
• Safekeeping of the assets acquired by the IPEs that are listed in the foreign securities quotation system
• Clearing and settlement of transactions
• Administration of property rights
• Representation of political rights
• Tax duties
• FX duties
• Information duties (to FX, inspection, surveillance and control authorities)
• Any other duties imposed from time to time by the inspection, surveillance and control authorities

This activity consists of maintaining due care and surveillance of the securities* and financial resources of the ILPs when transacting with such securities.

S3 CACEIS Colombia, as a Custodian of securities, will comply with the rules governing the securities custody activity. To this end, S3 CACEIS will perform the custody activities, depending on the investment vehicle to which the custody services will be applied, by providing at least the (legal) mandatory services:

• Mandatory services
• Safekeeping of securities
• Clearing and settlement of transactions
• Administration of property rights
• Mandatory services for collective investment undertakings (Fondos de Inversión Colectiva or FICs)

Besides these mandatory services, in the case of custody of securities belonging to the FICs, SC Colombia will verify compliance with the regulations, as well as the limits, restrictions and legal prohibitions applicable to FIC transactions involving securities held in custody, all according to the guidelines set by the SFC (Superintendencia Financiera de Colombia) regarding refrain from conducting prohibited instructions situations and, in any case, reporting to the SFC (the Self-regulatory body of the Colombian Securities Market) and the Management Board of the administration company of the relevant FIC, in due time and manner, any situations identified as non-compliant and situations reported as limit breaches and refrain from settling prohibited operations while fulfilling the Custody tasks assumed.

• Ancillary Services

Apart from the mandatory services above described, as far as S3 CACEIS Colombia provides these services, the provision of the following may be agreed too:

• • Administration of political rights

Other Ancillary and Special Services allowed by the current local regulations will be later available if required by the ILPs, as far as SC Colombia is the provider of the Mandatory Services for those portfolios and if the services have been approved through the relevant internal processes. These services are:

• • Ancillary Services
  • Valuation
  • Temporary transfer of securities
  • Tax obligations
  • FX obligations

• Special services
  • Valuation of the FIC portfolio and units
  •  Accounting of the FIC maintained in custody

Act 964 of 2005:

Article 2. Meaning of “security”. For the purposes of this law, “security” refers to any negotiable right that is part of an issue, when it is intended for the raising of funds from the public, including the following: a) shares; b) bonds; c) commercial paper; d) warehouse receipts; e) any title or right resulting from a securitization process; f) any title representing venture capital; g) term deposit certificates; h) bank acceptances; i) covered bonds; j) any public debt securities.

Paragraph 1. Insurance policies and “Capitalizing Bonds” are not considered to be securities.

Paragraph 3. The provisions of this law and its implementing or supplementing regulations shall apply to financial derivatives such as futures and option and swaps, as long as they are standardized and may be negotiated in the stock exchanges or other securities markets. The products referred to in this paragraph may be sold to the public only upon being registered in the National Registry of Securities and Issuers.

This is the service provided by S3 CACEIS Colombia to ILPs for investments in securities of foreign or domestic issuers that are purchased and kept abroad, and whose nature allows for a custody service. These will be fully maintained in custody in foreign banks that have been certified by S3 CACEIS Colombia according to global procedures.

The following services are provided for Custody of securities in other countries:

• Safekeeping of securities
• Clearing and Settlement
• Administration of property rights
• Administration of political rights
• Reporting
• Tax exemptions and claims