Policies and Procedures of Banco de Chile

The Bank’s Board of Directors has approved several Policies and Procedures containing the General Principles of Corporate Governance of Corporation Banco de Chile.

ome of the main Policies and Procedures approved by the Board are the following:

Management of Insider Information and Personal Investments.

The Board of Directors of Banco de Chile approved an Institutional Policy on Management of Insider Information and Personal Investments that governs the management of insider information held by directors, advisers and employees of the Bank and its subsidiaries, and the procedures applicable to their personal investments in certain publicly traded securities and, in particular, in securities issued by Banco de Chile. The main aspects of this policy are contained in the “Manual for Handling Information of Interest for the Market” indicated hereinbelow.

Pursuant to such policy, and notwithstanding the reserve and confidentiality obligations established in the law, any person affected by the policy shall keep strict reserve regarding any insider information held by such person or to which he/she has had access due to its title, position or activity.

Likewise, any person that has or may have access to the Bank’s financial statements before they become publicly known, shall not execute any transaction of shares issued by Banco de Chile, for a period that goes from the tenth day of each month and the moment in which the results of the prior month have been informed to the public in general, whether by the Chilean Financial Market Commission or by Banco de Chile.

This restriction shall affect the directors and advisers of Banco de Chile’s Board of Directors, the General Manager, Division Managers and those that due to their positions or duties participate in the preparation of or have access to the referred financial statements. Notwithstanding the foregoing, certain persons within the institution that due to their positions may potentially have access to financial information before the above referred date, whether because they directly participate in its preparation or because they participate in its initial approval, are subject to a special blockade period starting the fifth day of each month and until the moment in which the results of the prior month have been informed to the public in general, as indicated above.

Transactions with Affiliates of General Occurrence.

Notwithstanding the application of legal provisions on transactions with affiliates contained on the Law on Corporations, the Board of Banco de Chile approved, pursuant to the referred law, a Policy on Transactions with Affiliates of General Occurrence that establishes those transactions deemed regular transactions in accordance with the business purpose of the Bank and that, therefore, their execution is not subject to the requirements provided by Law No. 18,046 on Corporations. Such policy was informed as an essential fact to the Chilean Financial Market Commission.

See Policy on operations with affiliates of general and regular occurrence

Policy on Donation for Social Purposes and on Charity Donations.

This policy establishes a general framework of internal control regarding donations made under the applicable law and Corporate Social Responsibility (CSR), in which Banco de Chile or its Subsidiaries participate.

One of its main purposes is that any charity donation is made to entities not related with organizations of shady reputation, or that have negative backgrounds, whether for being related to money laundering, fraud or other illicit activity. For these safeguards, process assuring an adequate knowledge of the beneficiary and its representatives shall be executed.

Donations made by the Bank shall avoid the existence of possible conflicts of interest, whether with customers, investors or employees of the Bank.

In addition, the policy establishes the obligation of informing quarterly to the Directors and Audit Committee all such cases in which any member of the management or Board of Directors of the beneficiary Institution is a member of Banco de Chile’s Board of Directors, his/her spouse or blood relative or affine up to second degree, as well as for the cases in which the beneficiary Institution has an ownership relation with any director of the Bank or its related individuals. The same formality shall be applied in case of a manager or main executive of the Bank. In case of subsidiaries making donations, the same criteria shall apply.

Operaciones de Loan Transactions with Directors and Senior Executives.

The policy approved by the Board on this regard prohibits any kind of loan to directors and the General Attorney, as well as to their related persons, whether their spouses, under age children or companies in which they have an interest of more than 5%.

Likewise, for Divisional Managers and General Managers of Subsidiaries, the latter, whether or not they are legal representatives (with general authorities), may only be granted new credits, renewals and extensions under the limits established in this Policy. It should be noted that credits cannot be granted under more favorable deadlines, interest rates or guarantees than those granted to third parties in similar operations.

Policy on Non-Discriminatory Access to Loan Products for Individuals.

The purpose of this Policy is to establish guidelines to guarantee that Banco de Chile and Subsidiaries do not make any arbitrary discrimination with its customers when promoting, selling or evaluating loan products.

The Bank must make an adequate identification of the different credit products, keeping within the definition of its target market, selection criteria that in no case may be based on arbitrary discrimination. Banco de Chile does not discriminate on the access to loan products arbitrarily as to the following conditions: race, religion, sex, nationality, marital status, age and disability. Such offer of products or services directed to certain segments of the market and grounded on reasons of risk-return, profitability, market depth, strategic alliances and other reasons of similar nature shall in no case be considered an arbitrary discrimination.

Anti-Money Laundering and Prevention of Terrorism Financing.

The Board of Banco de Chile approved a Policy on Anti-Money Laundering and Prevention of Terrorism Financing which main purpose is to establish the minimum standards to reasonably protect and assure that Banco is not used as a means through which illegal income/funds circulate or intended to promote or finance terrorist activities. This policy provides the existence of an Anti-Money Laundering Committee (COPLA) whose main purpose is to comprehensively monitor, within the framework of its competence and scope, the process of Prevention of Money Laundering and Financing of Terrorism at the corporate level, trying to avoid and / or anticipate risk situations.

Prevention of Practices against Probity.

The Board of Banco de Chile approved a Policy on Prevention of Practices against Probity, which purpose is to establish the guidelines to guarantee compliance of the applicable regulation referred to gifts, invitations or any other benefit delivered to public, private or foreign officials, with the purposes of avoiding the possibility that any of these actions are against state probity or considered an attempt of bribery. The referred policy is based on the current criminal law and related provisions contained in the Code of Conduct of Banco de Chile.

Prohibitions on Product Conditioning.

The policy approved by the Board prohibits tied selling for certain products pursuant to the applicable law and regulations, including insurances. It also safeguards that customers are informed about their rights on this matter when contracting one or more products offered by the Bank or its affiliates.

Management of Legal Vehicles.

The purpose of this policy is to describe the legal rules established for the creation, management and administration of any subsidiary or related non-bank financial company (sociedad de apoyo al giro) of Banco de Chile, in accordance with the regulations of the Chilean Financial Market Commission and the General Bank Law. The creation of a subsidiary company must have an agreement of the Board of Directors of Banco de Chile.

Anti-boycott Practices.

The purpose of this policy is to describe the guidelines that govern Banco de Chile and its subsidiaries as to matters such as non-arbitrary discrimination and practices against arbitrary embargoes and/or boycotts. Likewise, this policy describes the business or areas of the Bank in which there may be any arbitrary discrimination and the manner in which our institution addresses this issue. In particular, this policy regulates credit processes in favor of individuals, personnel selection and foreign trade operations.

Operational Risk.

In this policy, the global framework for the management of Operational Risk in Bank of Chile and its subsidiaries is defined, establishing the principles for its identification, evaluation, control, mitigation and monitoring.

Operational Risk is the risk of losses resulting from a lack of adequacy or a failure of processes - of the personnel and / or the internal systems - or due to external events. This definition includes legal risk and excludes strategic and reputational risk. In this context, Operational Risk will be managed as a different category of Risk, independent of Credit Risk and Financial Risks.

Criminal Prevention Model - Law 20.393 Liability of Legal Entities (Modelo de Prevención de Delitos Ley 20.393)

Banco de Chile has approved a model of organization, administration and supervision aimed at preventing the crimes established in Law 20.393 on Criminal Liability of Legal Persons.

The model aims to describe the methodology, corporate instances and main elements established to prevent the crimes identified in the law and likewise, this model determines the behavior criteria to be followed by the members of the Corporation to comply with the provisions of the referred rule.

Policy on Environmental Sustainability.

Sustainable development is a priority for Banco de Chile and, especially, the impact on the environment, through the direct or indirect consumption of natural resources.

Financial institutions in general, and banks in particular, have a key role as dynamizers of the economic system and seek to contribute and impact on people's quality of life, addressing the different needs and objectives of society through products and services.

The purpose of this policy is to urge to reduce the impact on the environment, contributing to financial stability and achieving the country's commitments in the matter.