ESG Information

Responsible Action Policy

Management and Sustainability Report - 5.3 Risk Management

Supplementary Risk Management Document

Supplementary Environmental Management Document

Management and Sustainability Report -  9.2 Environmental Management

Within the framework of the 5 environmental programs that Findeter has, the environmental campaign "Be Aware" is developed under the slogan "With your feet on the ground". This in order to disseminate the various awareness and education activities supported by the different internal communication channels that the Entity has and the different face-to-face campaigns that arise according to the needs that arise.

Findeter, within the framework of its Sustainable Practices Program, annually measures its corporate carbon footprint and offsets 100% of the quantified greenhouse gas emissions.

Management and Sustainability Report - 9.2 Environmental Management

Management and Sustainability Report -9.2 Environmental Management

As an Issuer of Group A before the National Registry of Securities and Issuers - RNVE and in response to the Competitive Business Program and Circular 031 of 2021 SFC led by the Ministry of Finance and Public Credit, information on our management and performance in climate change is included in approximation and in accordance with the recommendations of the TCFD (Task Force on Climate-Related Financial Disclosure). Disclosure is based on four fundamental pillars: Governance, Strategy, Risk Management and Metrics and Objectives.

Management and Sustainability Report - 13.3.3 TCFD

Management of risks and opportunities in the face of climatic phenomena (identification and evaluation)

Management of physical and transition risks in the face of climatic phenomena (mitigation)

Emergency and Contingency Plan 

Supplementary Environmental Management Document

Management of opportunities in the face of climatic phenomena (identification and evaluation)

Emergency and Contingency Plan 

Supplementary Environmental Management Document

Management of opportunities in the face of climatic phenomena (implementation)

Emergency and Contingency Plan 

Supplementary Environmental Management Document 

The Green and Sustainable Reactive line was created as an opportunity to help face climate change.  Its eligibility criteria is given under green taxonomy issued by FINDETER. The resources are available through a line of credit that benefits private and public companies, municipalities, governments and national and regional decentralized entities, which may invest in initiatives in the energy, transportation, urban development, construction, housing, education and technologies sectors. With this line FINDETER hopes to contribute to the mitigation and adaptation to climate change through the opportunity of financing projects that reduce greenhouse gas emissions and/or that make it possible to reduce the risk vulnerability of natural systems, achieving the country's environmental objectives and commitments.

Energy efficiency credit line: In order to leverage the purposes of the national Government framed in the National Development Plan “Colombia World Power for Life 2022-2026”, support the commitments that the country acquired internationally in the National Determined Contribution (NDC), which is mainly aimed at reducing greenhouse gas emissions, and contributing to solving problems in social, economic and environmental aspects in the energy sector, Findeter makes available a rediscount line with a compensated rate to support the need for resources for working capital of companies in the Energy sector and investment in: 1. Energy efficiency and transition projects 2. Renewable energy projects 3. Electromobility projects 4. Virtual connectivity projects 5. generation, commercialization, distribution, transmission and storage of energy.

Incentives policy related to environmental management, including climate

We have a Sustainable Procurement Policy in place to establish guidelines for the procurement of sustainable goods and/or services, aiming for their rational and efficient use (Management and Sustainability Report). Likewise, we maintain Environmental Education Policies and various environmental programs—covering sustainable practices, efficient energy, water, and paper use, and comprehensive waste management—designed to raise environmental awareness and promote the efficient use of natural resources, thereby helping to reduce the Entity's carbon footprint. However, given the nature of Findeter’s financial business, we implement these measures internally while consistently promoting sustainability in our products and projects.

Regarding the Sustainability Strategy, Findeter’s areas of focus were defined by considering synergies with its strategic business plan and core mission, industry best practices (benchmarking), the diagnostic process, and the organization’s materiality analysis. This resulted in the establishment of four key areas of action: climate action, natural capital, the circular economy, and sustainable territorial development.

As part of its sustainability objectives concerning eco-efficiency and the circular economy in internal operations, Findeter has set a goal for 10% of its facilities to meet sustainability criteria by 2030. Additionally, regarding circular and sustainable procurement, the organization aims to implement sustainable purchasing criteria for 50% of prioritized goods and services by the end of 2025.

Management and Sustainability Report - 9.2 Environmental Management

Findeter operates five environmental programs, including the Efficient Water Use Program. Within this framework, we established a Per Capita Water Consumption indicator to measure our performance in water resource management, expressed in cubic meters (m³) per employee. In 2025, this indicator showed an average result of 0.50 m³/person per month—well within the target of 0.9 m³/person per month—thereby successfully meeting our objectives for water conservation and efficient use. The target for 2026 is 0.8 m³/person per month.

To manage water resources, we implement actions that support the achievement of our projected and annually defined targets. Key measures within our Efficient Water Use Program include installing water-saving devices on faucets and toilets, performing preventive and corrective maintenance on plumbing systems, using cyclical garden irrigation systems, and raising environmental awareness to foster a culture of conservation during activities such as brushing teeth, washing hands, and watering plants. Please note that this target may be adjusted should significant organizational changes occur that result in drastic variations in consumption levels.

Management and Sustainability Report - 9.2 Environmental Management, 9.2.5.2 Positive impact on biodiversity

Management and Sustainability Report -  Environmental and Social Risk Management System (SARAS): The SARAS system aims to identify, evaluate, and control environmental and social impacts, including bioversity, gender and climate change aspects, generated by the projects and/or investments financed by Findeter. 

See SARAS description. 

Management and Sustainability Report - 9.2 Environmental Management

Supplementary Environmental Management Document

As issuers of securities, in Findeter we have the objective  of integrating environmental, social and economic criteria in decision-making and in the offer of financial products and services for territorial development. We have a Responsible Finance work cell in order to manage the organization's best sustainability practices through cross-section work in the organization. 

Annual report on Sustainable Bonds

Management and Sustainability Report - 10 Stakeholders managemen

Management and Sustainability Report - 7.7  Right of Association

Collective Labor Agreement in force, Integrated Management System.

Stakeholder Engagement Management

9.3.1 Responsible Action 10 Stakeholders management 12 Performance on material topics (GRI – SASB – TCFD)

Our procurement processes correspond to a Private Law Regime in accordance with the development and fulfillment of the approaches that  govern the administrative duty and  Fiscal Management set forth in articles 209 and 267 of the Political Constitution, as well the provisions of the Code of Ethics and Corporate Governance, mainly in the principles of economics, efficiency, effectiveness, equality, impartiality, morality, advertising, equity and assessment of environmental costs. See the policy

Responsible Action / Sustainability Policy: establishes obligations regarding ESG due diligence, social and environmental responsibility, impact prevention and mitigation, and the inclusion of ESG criteria in project evaluation; stakeholder engagement; human rights, gender equity, social inclusion, and fair treatment for all. It also covers sustainable procurement: acquisitions that take social and environmental criteria into account.

Sustainability Strategy: We utilize a sustainable sourcing indicator, which stipulates that Findeter will implement sustainable purchasing criteria in at least 50% of prioritized procurement processes.

Management and Sustainability Report - 4.2.1.4 Supplier Code of Conduct

Our management systems inlude a Supervision and Auditing Manual,  which provides  guides and tools  on FINDETER suppliers and contractors, the manual can be consulted here: See the Manual 

Numeral 8.8 -Knowledge and Due diligence SARLAFT. FINDETER within its policy of knowledge and due diligence of suppliers, within the framework of the prevention of the risks of Money Laundering and Terrorism Financing, prior to hiring an employee and during the contractual relationship, FINDETER performs the verification on binding and informative lists such as: United Nations Security Council, OFAC, European Union, DEA, United Kingdom, Single List of France, Panama Papers, Interpol, in addition to national lists such as , Attorney's Office, Comptroller's Office, judicial branch, national convictions, fiscal responsibility, sanctions against contractors (SECOP), DIAN, national police, among others.  

Also, a Risk Matrix is made for each contract, which establishes the performance bonds. 

Likewise, with the tools established in the Supervision and Auditing Manual, contractual risk management is carried out for each of our suppliers and contractors.

Management and Sustainability Report - 5.3 Non-Financial Risk System

Management and Sustainability Report - 10 Commitment to Findeter's Stakeholders. Suppliers are identified as one of Findeter's Stakeholders. Therefore, as an organization, we are committed to maintaining relationships of trust with efficiency and opportunity through transparent and timely dialogue.

Findeter has a Financial Consumer Service Manual-SAC.

In 2025, there were no situations subject to sanctions, in accordance with the provisions of the SAC Manual.

Findeter's human talent management policy aims to have the right people, to strive for their development, for their quality of life, and to provide adequate spaces and resources for the performance of different roles and responsibilities. Thus, from the processes of identifying the personnel needs that are required and inquiring about the interests of the collaborators, through well-being activities, aspects that are frequently measured, through the work environment survey, internal customer satisfaction and external measurements and other first-hand measurements that provide valuable information to keep employees identified and committed to Findeter's policies. With all of the above coupled with the vision of the company that focuses on the development of the country, sustainability and its contribution to the community, it allows us to retain key personnel to achieve institutional goals.

Family Responsible Company (Efr) management model: Equal Oportunities.

Management and Sustainability Report - 7 Human talent management

Employee turnover rate 

Diversity and inclusion and gender equality policy, program or actions

Good Governance Code: The Gender Equity and Social Inclusion Policy is defined (Section 11.5 Gender Equity and Social Inclusion Policy) and it indicates that "it is committed to promoting and developing a culture of gender equity and empowerment of women in its stakeholders in order to positively impact the social and environmental settings where we are present.

Management and Sustainability Report - 7 Human talent management

In our Integrated Management System we have the Manual of Duties, Competencies and General Requirements, which defines the policies for Salary remuneration in accordance with the provisions of this manual, respecting gender equality, prioritizing the years work experience and requirements for the position.

Programs or actions for the empowerment and development of female leadership

Management and Sustainability Report - 4.5.3 Programs or actions for the empowerment and development of female leadership

For the 2025 term, we are continuing to run the LIT Leadership School—"Inclusive and Transformational Leaders"—with a new cohort of leaders who are new to the organization.

Recruitment Policy (Integrated Management System). Within the company, in order to cover vacancies, we first verify if there is availability of human resources internally, for which an Internal Call process is carried out to give opportunity tp all staff, both direct and temporary, to participate promoting integrity and equality.

The profile is published in the internal communications channel with all the basic requirements in terms of education, training, experience, skills and salary, which allows the different candidates to send the supporting documents to the Head of Human Resources to validate their compliance with the profile and begin the selection process.

See Internal promotions by gender table 111 (pg 288)

Family Responsible Company (Efr) management model: Development and Professional Competence

Prevention and Attention Protocol against Sexual Harassment

Good Governance Code: The Gender Equity and Social Inclusion Policy is defined (Section 11.5 Gender Equity and Social Inclusion Policy) and it indicates that "it is committed to promoting and developing a culture of gender equity and empowerment of women in its stakeholders in order to positively impact the social and environmental settings where we are present. 

Management and Sustainability Report - 4.5.4 Prevention and Attention Protocol against Sexual Harassment

Long-term incentives for employees

Family Responsible Company (Efr) management model: There are 61 measures that benefit and encourage employees to remain within the entity in the long term, such as preferential rates for credits for serving a minimum of years within the entity.

Employee loyalty and sense of belonging - engagement (Measurement)

Engagement is an effect that is defined as the positive affective bond with the job characterized by effort, dedication and absorption. We measured this phenomenon through the FPS battery of the consulting company Siete Human and Organizational Management in May 2022 and it is valid for 2 years.

Management and Sustainability Report - 6.8.6 Health and Safety at Work

Accident rate indicator pg 294 Table 114. Absenteeism Levels – 2025

We have an Indicator in the Integrated Management System, whose source of information is the reported disabilities, whether of general or labor origin,  periodically reported within the entity in the Management System.

Absenteeism rate indicator pg 294 Table 114. Absenteeism Levels – 2025

We have an Indicator in the Integrated Management System, whose source of information is the reported disabilities, whether of general or labor origin, periodically reported within the entity in the Management System.

Disability rate indicator pg 294 Table 114. Absenteeism Levels – 2025