Manual of Procedures for the Prevention of Money Laundering and Financing of Terrorism

Introduction

The Comprehensive Prevention System adopted by Delta Servicios Financieros (Centro Sudamericano SA), contained in this Manual, approved by a Board resolution dated May 12, 2009 and subsequent amendments, includes prevention and control policies and procedures, as well as the organic structures established by the Company, in order to prevent it from being used in maneuvers aimed at legitimizing assets from criminal activities, financing terrorism and financing the proliferation of weapons of mass destruction (LA / FT / FP).

In this regard, the Board of Directors of Delta Servicios Financieros (Centro Sudamericano S.A.) adopted the Declaration of Principles set forth below, as a sign of the high degree of commitment of the highest levels of driving the company with prevention tasks.

Declaration of Principles

“Delta Servicios Financieros (Centro Sudamericano SA) has decided to adapt and update its Prevention System against Money Laundering, Terrorist Financing and the Proliferation of Weapons of Mass Destruction, due to the changes that have occurred in national legislation, as well as those observed in the international field. With this, Delta Servicios Financieros (Centro Sudamericano SA) expresses its firm belief that the policies adopted will reduce the risks of the company being used in maneuvers for criminal purposes and may contribute to the efforts of regulatory and law enforcement agencies in the fight against the monetary and economic aspects of crime and terrorism.

For this reason, Delta Servicios Financieros (Centro Sudamericano S.A) has adopted a Comprehensive Prevention System against this type of scourge, which includes among others:

• Strict customer identification and knowledge procedures (KYC)
• Formal and written policies for prevention of money laundering, terrorist financing and financing of the proliferation of weapons of mass destruction
• Appointment of a responsible anti-laundering selected among their senior managers (Compliance Officer)
• Monitoring systems and periodic review of transactions
• Permanent training and updating programs for its officials and staff
• Annual External Audit in order to evaluate the Prevention System implemented.

The fight against money laundering, the financing of terrorist activities and the financing of the proliferation of weapons of mass destruction is a priority within our organization and no utility or source of business can be justified if it runs the risk of helping those They intend to use our services for transactions with assets of illicit origin or destination.

Our ethical commitment implies, at the same time as collaborating in the fight against the aforementioned crimes, to recognize that our company operates within the framework of the authorization received, whose purpose is the generation of profits by lawful means and that its officials and clients fit its activities under the law and regulations in force.

The effectiveness of the Prevention System adopted will depend, fundamentally, on the degree of collaboration of all company personnel and their conviction regarding the need and convenience of its application. This requires not only knowledge of the internal norms implemented as part of it, but of their permanent disposition to be alert to possible money laundering maneuvers, the financing of terrorist activities or the financing of the proliferation of weapons of mass destruction. .
The Directorate is aware that nothing can replace the insightful and knowledgeable official of its activity and is willing to give the example of its decision to avoid criminal maneuvers.

Without prejudice to the policies, procedures and controls contained in this Prevention System, the basic element to prevent our company from being used in illegal maneuvers is the knowledge that each official must have, within their specific responsibility, of their own activity and of the clientele.

That knowledge should not be limited to purely formal aspects but should be extended to the understanding of the nature of their business and translated into a permanent evaluation of the reasonableness of the operations that our clients perform.

Strict compliance with the prevention tasks assigned to each of our officials will be an inexcusable condition for the preservation of the job and any deviation, if it does not consist of a violation or formal offense, will be sanctioned administratively. For these reasons and for the achievement of these purposes we request the widest collaboration of all our officials. ”

 

Montevideo, October 21, 2014

Mrs. Ana María Rumi Mr. Rafael Barbieri Rumi

President Vice President

GOALS

The System adopted by Delta Servicios Financieros (Centro Sudamericano S.A.) aims to:

Establish prevention and control policies and procedures that ensure full compliance with current norms and regulations.
Assure customers that the company applies the best prevention practices, in accordance with national standards and major international standards.
Apply a Customer Due Diligence policy that allows, to know the effective beneficiary of the transactions and the origin of the funds it manages.
Implement policies and procedures regarding the personnel of the Company that ensure a high level of integrity of the Company, as well as its continuing education and training in prevention of ML and FT.

Maintain adequate documentary support, which enables the reconstruction of operations in accordance with current legislation.
Timely report to the Financial Information and Analysis Unit (hereinafter UIAF) of the BCU, unusual or suspicious transactions, under the terms of article 1 of Law 17.835 and the regulations issued by the BCU (art. 422.17 RNRCSF and Communication No . 2005/044).
Comply with the obligation to inform the UIAF if the existence of assets linked to terrorists or terrorist organizations is verified, under the terms of article 17 of Law 17.835 and article 422.18 of the R.N.R.C.S.F.

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Personnel Code of Conduct

The Code of Conduct that the institution has, is developed based on the legal, regulatory provisions and within the context of the Prevention of Money Laundering and Terrorism Financing System of Delta Servicios Financiers, on which the Institution, its managers and All its officials guide their actions. It is based on the following institutional principles:

Respect: our organization operates on the basis of respect and commitment to the entire organization and its members, its customers, suppliers and the
society as a whole.

Integrity: our organization demands that its personnel develop their activities with honesty, sincerity and credibility.

Professionalism: our organization intends for its staff a professional performance according to its function, in order to provide its
Customers efficient service and superior quality.

Sustainability: The board and the staff of our organization aim to generate a sustainable development of the organization and through it
Contribute to the development of society.

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Manual of Good Practices

With the adoption of this Code of Good Practices, Centro Sudamericano SA, intends to establish a frame of reference for the relationship between the Client and our institution, promoting the transparency of the information provided in relation to the products and services it provides and establishing standards of good practices.

This Code implies the commitment to follow the rules included in it and to comply with the obligations contracted for the benefit of the Client. This will not impede the permanent improvement of the levels of transparency and quality of services provided by Centro Sudamericano S.A.

In this regard, this Code will be reviewed and updated, when necessary, in order to foster the trust of customers and regulators. We understand that the incorporation of this Code contributes to the rights of customers of Centro Sudamericano S.A. Keep consolidating.

The Code of Good Practices is part of the policies that govern the actions of Centro Sudamericano S.A., not having as its object the revocation or replacement of the provisions contained in other internal norms, but their complementation.

Centro Sudamericano S.A. adheres to the Code of Good Practices of the Chamber of Financial Services Companies of Uruguay – August 19, 2014 –

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