Compliance and Regulation

Official Language

The official language of the documentation and all written material belonging to IPOS S.A. is Spanish. These include contracts, the webpage and any other legal or tax material. Any material belonging to IPOS S.A. found in another language shall be considered a translation of the official language.

Corporate Commitment

a. IPOS S.A. is committed to developing its business, under strict compliance with the laws of the country and international treaties ratified by Paraguay. Consequently, it is committed to undertake the necessary steps to verify the identity of their customers and the source of their investments, in accordance with current legislation.

In terms of terrorism prevention, Paraguay has enacted Law 4024/10, which punishes Terrorism offenses, Terrorist Association and Terrorism Financing. Paraguay has passed Law 2381/2004, approving the International Convention for the Suppression of the Financing of Terrorism, and Law 2330/2003 approving the Inter-American Convention against Terrorism.

In relation to drug trafficking, Paraguay has enacted Law 16/1990 which approves and ratifies the United Nations Convention against Illicit Traffic in Narcotic Drugs, Law 108/1991 creating the National Anti-Drug Secretariat, and the law 717/1995 approving the Convention on Mutual Assistance with the British Government in relation to drug trafficking.

In the area of money laundering, Paraguay has enacted Law 1015/1997 to prevent and suppress unlawful acts intended to legitimize money or property and Law 4100/2010 approving the Memorandum of Understanding between the governments of the states in the Financial Action Task Force of South America against Money Laundering (GAFISUD), among others.

It should be noted that Paraguay remains off the blacklist of "high-risk and uncooperative jurisdictions" that is periodically publishes by the Financial Action Task Force on Money Laundering (FATF) which is the governmental institution created by the G7 to develop policies to help combat money laundering and terrorist financing. (Source:http://www.fatf-gafi.org/topics/high-riskandnon-cooperativejurisdictions/documents/fatfpublicstatement-16february2012.html).

b. IPOS S.A. is committed to the principles that make up the Global Compact on Corporate Social Responsibility, which provide for the respect and encouragement of business in the following areas:

- Human Rights: IPOS S.A. is committed to support and respect human rights within their sphere of influence.

- Labor Rights: IPOS S.A. is committed to promote the continuing training of its employees, and promoting opportunities for professional growth. IPOS S.A. is absolutely committed to contribute to the elimination of all forms of child labor in violation of labor laws and laws pertaining to children and adolescents.

- Environmental Protection: IPOS S.A. is committed to environmental care within its sphere of influence, as well as using environmental resources efficiently and sustainably, ensuring a minimum impact on the environment and promoting the use of technologies that respect the environment.

- Fight against corruption: IPOS S.A. undertakes to exercise honest and transparent corporate practices and reject corruption in all its forms.

c. By all the commitments set forth in this section, IPOS S.A. refuses to conduct business or engage with individuals or legal entities engaged in activities that contravene the laws in force in the Republic of Paraguay, international agreements on Corporate Social Responsibility, or engage in any activity that may harm the reputation of IPOS S.A. Accordingly, IPOS S.A. reserves the right of admission of clients and professionals, and anyone else with whom business relationships may have begun after a preliminary verification of compliance with the above matters.

Accountability Regime

IPOS S.A. operates as an intermediary company hiring professional services rendered by independent, specialized professionals for client companies. IPOS S.A. is also responsible for administrative matters relating to the hired professionals.

The hired professionals are fully responsible for the services they provide, at their own risk, as the independent service providers.

Confidentiality

Any information provided by customers or professionals, will be treated by IPOS S.A. as "Confidential Information". IPOS S.A. agrees not to disclose said information and will make every effort to prevent the use, publication and disclosure of any information as considered secret or confidential related to the clients and professionals. IPOS S.A. agrees not to provide, transmit, publish, reproduce, or make known to third parties, Confidential Information, except as follows:

A) To perform the service for which IPOS SA was hired.

B) IPOS S.A. may provide Confidential Information only to its own staff, and only in cases in which it is needed in order for them to carry out their tasks. Similarly, IPOS S.A. is committed to giving instructions to its own staff in relation to the confidentiality that should be kept regarding Confidential Information and penalties which are subject to non-compliance.

C) In any case in which IPOS S.A. is bound by administrative action or court order to deliver all or part of the Confidential Information. IPOS S.A. must communicate this in writing to the owner of the information when it becomes aware of said request.

D) In any case in which the owner of the Confidential Information authorizes IPOS S.A., in writing, to do so.

The information provided will not be considered “Confidential” only if it becomes known for any of the following reasons:

A) That the information is in the public domain.

B) When the information has come into the public domain by means other than through IPOS S.A.

The information provided will not be considered “Confidential” only if it becomes known for any of the following reasons: