Compliance Program

China Communications Construction Company Limited (CCCC), China Harbour Engineering Company Limited (CHEC) and its subsidiaries and related companies including METRO LINEA 1 S.A.S. (“ML1”), have legally implemented a compliance program (“Compliance Program”) that complies with the best standards of international compliance and ethical practices.

The CCCC Compliance Program is properly designed and implemented to determine and mitigate any compliance risks that CCCC and its subsidiaries or related companies including ML1, face day by day in the execution of their activities. This program includes within its scope, among others, the implementation of existing policies, processes, practices and other actions that act to minimize the risk of Money Laundering and Terrorist Financing (ML/FT) in the operations, businesses or contracts carried out by CCCC and its subsidiaries and related companies including ML1.

ML1 as a subsidiary company of CHEC and related company of CCCC, has currently implemented and developed the CCCC Compliance Program. Likewise, this program is being improved, under the requirements, standards, terms and conditions of the Multilateral Entities, that is, the World Bank, Inter-American Development Bank -IADB -, International Bank for Reconstruction and Development -IBRD-, and European Investment Bank  -EIB-, as well as the Concession Agreement No. 163 of 2019 signed with Empresa Metro de Bogotá SA, its Technical Appendices and Annexes, as well as the recommendations of the Group of International Financial Action -GAFI- and regional level by the International Financial Action Group of South America -GAFISUD-, the Superintendency of Corporations, the Financial Information and Analysis Unit - UIAF and other control authorities in Colombia.

Finally, ML1 will adopt the best ML/FT prevention policies and measures for proper self-control and risk management in daily operations. For which it will have a staff with experience in self-control and risk management system, for the efficient, effective and timely operation of the company.

08/24/2021