How to make your report or inquiry successful?

Stay in contact: Being able to contact the whistleblower is a key factor for the success of an investigation. That's why it's important that you follow up on your report or inquiry so you can track the progress of the process, respond to our questions, or provide additional information. You can leave us a means of contact without revealing your identity.

Tell us all the details: The more information you provide, the higher the chances of confirmation.
Keep these recommendations in mind:

• Use channels such as the phone line, email or the EthicsGlobal chat, where you can interact with agents who will help you file your report.
• Provide the names of the people involved or who may have knowledge of the incident.
• Describe the place and date where the events occurred.
• If possible, provide elements that can serve as evidence.
• Write a detailed description of the events.

How can I track a report or inquiry I have submitted?

When you finish filing your report or inquiry, you will receive a reference number. With this number, you can track the status of the process and check any messages we may have sent you in case you chose not to provide your contact details. You can track it at any time.

How long will it take to resolve a report or inquiry that has already been submitted?

EthicsGlobal makes the information available to the corresponding Compliance officer within a maximum of 24 hours after the report or inquiry has been submitted. Once received, the company will analyze the situation to resolve the case.

How Does It Work?

The reception of reports and inquiries is managed by EthicsGlobal, an external company completely independent from SURA Asset Management (SURA AM) and specialized in this field. This ensures transparency and seriousness in ethical management while respecting whistleblowers' rights.

We have various channels for receiving reports or inquiries to the Ethics Line, all of which are managed by EthicsGlobal:

1. Through this portal, you can fill out a form that requests all the necessary information to conduct the investigation.

2. By phone, through the following numbers:

   
   

   Chile	0800-914-501
   Colombia	01-800-5189191
   Mexico	800-04-38422

   Peru	0800-78424
   Uruguay	000-416-205-6395

   
   
   

   You will be assisted by an expert in handling ethical reports and inquiries from EthicsGlobal.

3. You can also submit your report or inquiry by emailing sura-am@sistemaetico.com or through the Chat you’ll find on the platform.

Regardless of the channel you choose, all reports or inquiries will be treated confidentially, and anonymity is guaranteed for whistleblowers who request it.

A. Reception

Reports may be submitted through the various channels established by the Company and will be centralized by the Compliance area, which will be responsible for gathering information and, when possible, seeking as much detail as possible about the events.

The Whistleblower may file the report anonymously. However, in cases where they choose to reveal their identity, the Company will guarantee strict confidentiality and will establish measures to prevent retaliation against them.

Each report will be identified with a unique case or file number, which will be sequential according to when it was received.

B. Classification and Referral

Reports received by the Company through any of the enabled channels will be classified according to the subject matter referenced.

Once a report is received, when appropriate, the Company will be responsible for referring the Report to the Responsible Area.

C. Responsible Area for Management

According to the classification of the Report, the Responsible Area will be in charge of channeling and processing the assigned reports.

D. Submission of the Report to the Ethics Committee

If the report refers to any member of Senior Management and/or the Board of Directors, it must be reported directly to the local Ethics Committee.

If the report concerns any member of the local or regional Ethics Committee of SURA AM, the Committee will be immediately notified, requesting the reported member to abstain from the session, so that the Committee can analyze and decide on the matter.

Similarly, in any of the above cases, the Regional Vice President of Legal, Compliance, Business Risks and IT of SURA Asset Management must be informed of this situation, who may or may not intervene in the investigation strategy, as well as in the report to the regional Ethics Committee of SURA AM.

The activities of spreading unfounded rumors, submitting reports, or providing deliberately false or misleading information will be subject to monitoring and review. If bad faith in the reported complaint is proven, they may be subject to disciplinary measures in accordance with the Internal Work Regulations adopted by the Company.

E. Investigation

The Companies shall have the authority to request any information they deem appropriate, provided it is sufficient and relevant to address the investigation as they consider necessary. For this purpose, they may utilize internal business areas that are owners or experts in the subject matter to be clarified, as stipulated in the Regional Ethics Line Policy of SURA Asset Management.

During the investigation procedure, the Companies shall determine the rules for engaging external parties or third parties, referring to all those actions that contribute to obtaining suitable evidentiary elements related to the investigated facts for the verification of any irregular conduct. These may include, but are not limited to, network connections, audits, recognition or inspection, requests for expert opinions or services, certifications before public notaries, among others.

For matters that by their nature must comply with regulatory provisions, the Companies may establish procedures related to handling reports for personnel in the Commercial area, Executives, Advisors, Promotional Agents, among others.

F. Implementation of the investigation work plan

The Company adopts a methodology that distinguishes the following minimum investigation stages:

• Planning. Preliminary stage aimed at defining the scope, information requirements, among others, which concludes with the activities to be developed and is limited to the framework of the investigation by generating hypotheses.
• Execution or Development: This is the stage where the activities of the investigation plan are carried out.
• Report. Documenting the main elements that constitute the investigation work, such as background, conclusions or findings based on the collected evidence.

G. Report to the Ethics Committee

The Committee must be aware of and, where appropriate, assist in resolving reports made through the channels that the Company has established for this purpose. For this, it will have the support of the areas it deems necessary, in accordance with the provisions of the Codes of Conduct and regulations of said committees.

When appropriate, depending on the relevance of the matter, the Ethics Committee may act as a consulting body to resolve concerns about reports, investigations or any matter related to the ethics line, or ethical issues, as well as propose recommendations for appropriate remediation actions that contribute to fostering the ethical culture of the organization.

H. Criminal Report

When during the report management process it is identified that the investigated facts may constitute conduct that according to applicable legislation could be considered a crime, the Company will file a report with the competent authority and carry out all actions indicated by said entity.

Inquiries received through the contact channels established by the Company that are related to the application of the Code of Conduct or internal policies that implement it, will be processed by the Compliance area, which will be responsible for carrying out the necessary procedures to resolve them.