Popular has always been distinguished for the integrity and honesty with which we do business and engage with our employees, customers, shareholders, and the communities we serve. Further to our commitment to these standards, Popular has available the EthicsPoint system.

Through EthicsPoint, our employees, customers, suppliers, investors and the community may report, anonymously and confidentially, situations or concerns associated with possible unethical conduct related to Popular with the purpose of solving them promptly and appropriately.

Reports may be presented through EthicsPoint under the following categories:

• Accounting, Auditing or Financial Reporting
• Bank Secrecy Act (“BSA”) and Anti-Money Laundering Laws (“AML”)
• Unfair, Deceptive or Abusive Acts or Practices against Consumers (including Sales Practices)
• Procurement and Purchasing Practices
• Other Matters, Policies, Laws and Regulations
• Employment-related Matters, including:

• Conflicts of Interest
• Discrimination or Harassment
• Retaliation
• Unsafe Working Conditions
• Inappropriate Use of Electronic Systems
• Other Employment-related Matters

EthicsPoint is available 24 hours a day, seven days a week, and may be accessed:

• Through the internet

        Spanish: www.popular.com/ethicspoint

        English: www.popular.com/ethicspoint-en

• Or by telephone (toll free):

        1-866-737-6813 from Puerto Rico, the United States or U.S. Virgin Islands

        1-833-416-6777 from Puerto Rico

        1-833-439-1392 from British Virgin Islands

        01-800-519-0915 from Colombia

        0-800-032-0114 from Costa Rica