Internal rules of conduct

Specific circumstances that give rise to the legal obligation to have the regulation in place

These Internal Rules of Conduct (hereinafter referred to as IRC) set forth the rules to which INSTITUTO DE VALORACIONES, S.A., an appraisal company approved by the Bank of Spain under number 4498 (hereinafter referred to as the Company) is subject, as one of the mechanisms applied by the Company to favor the independence of the appraisal activity and avoid conflicts of interest.

It is prepared on a VOLUNTARY basis and shall be applied in any case, even when the Company is not legally obliged to have a RIC, in accordance with the provisions of Article 3.2 of Law 2/1981, of March 25, 1981, regulating the mortgage market, especially because it does not have, among its customers, a credit institution customer or a group of credit institutions of the same group that has exceeded 10% of the Company’s turnover in a specific fiscal year.

For the same purposes, it is hereby stated for the record that the Company, as of the date of approval of these Regulations, does have controlling shareholders, or shareholders with a significant shareholding, with indirect interests in the development or marketing of real estate or similar activities.

Principles and objectives underlying the regulation

To this end, at least the following ethical principles, which are further developed below, must be observed:

Confidentiality: The Company and the professionals rendering services to it shall maintain professional secrecy with respect to the information obtained as a result of their professional and business relationships, and shall not disclose such information to third parties without the express authorization of the client unless there is a legal or professional obligation to disclose such information. Nor may it use the information received for its own
Integrity: The Company and those who provide services to it will be straightforward and honest in their professional and business relationships and will be guided by the best interests of the client and, within the framework of mortgage market legislation or others that so require, by the public interest.

Independence and objectivity: The actions of the Company and of those who provide services to it in the scope of its appraisal activity must be governed exclusively by technical criteria. The Company shall not allow conflicts of interest, undue influence or bias to nullify or impair their professional independence.

Competencia profesional: La Sociedad dispondrá en todo momento de los medios técnicos y humanos necesarios para asegurar que sus clientes, obtienen una valoración basada en la práctica más avanzada, la legislación aplicable, y las técnicas y metodologías más apropiadas al Con el mismo fin mantendrá los conocimientos y habilidades profesionales adecuadas al ámbito de negocio en el que opere.
Professional Behavior: The Company and the professionals rendering its services shall act with diligence in the fulfillment of the assignments, respecting what has been agreed and what is legally established, and the standards of the profession, trying to avoid discrediting the profession.
Transparency: This RIC will appear on the Company’s website and will be available to any customer who requests it.

Material scope of the regulation

The RIC will be applied to the appraisal of real estate assets that are to take effect in the mortgage market, or that are intended to meet orders placed by financial institutions, whether they are banks, savings banks, credit cooperatives, credit financial institutions, collective investment institutions or insurance companies, as well as to all other appraisals, whether of real estate, movable or intangible assets that the Company may perform and, in general, to all of its activities.

Subjective scope of the regulation

The RIC will affect the behavior of appraisers and technicians who provide their services to the Company, either as employees or as independent professionals, as well as the Company’s shareholders, directors and senior managers, members of its control bodies and, in general, all its employees and regular collaborators. Compliance with the ICR shall be incorporated into contracts for the provision of professional services carried out by the Company.

Consequences y penalties for non-compliance

These regulations shall apply, in general, to shareholders, members of the Board of Directors, Officers and Directors, company personnel who carry out activities that may fundamentally influence the appraisal values performed by the Company and the professionals who provide them with their services.

The Company and the Subject Persons accept the contents of the Regulations and undertake to strictly follow them. The Company shall strictly abide by the rules of conduct set forth in these regulations and shall require its employees and the professionals who provide services to them to behave in a similar manner insofar as they are concerned.

Likewise, in order to ensure perfect knowledge of and compliance with its provisions, these regulations shall be disclosed to all employees and professionals who render their services to the Company and accreditation of their knowledge shall be required in their personal files.

The Company will continuously evaluate compliance with these rules of conduct by professionals providing valuation services, investigating and resolving any complaints that may be received by the Company’s Customer Service Department about them. This evaluation will be just as important as the evaluation of the technical performance of the professionals when it comes to keeping them active in the Company.

The following shall be considered very serious misconduct:

Failure to comply with the Company’s professional secrecy obligations and the incompatibilities of freelance and independent professionals.
Non-compliance with internal rules for which the breach of professional independence of shareholders or shareholders’ representatives is demonstrated.
Failure of the signatories of the appraisal reports to comply with the professional qualification requirements
The lack of truthfulness in the issuance of certificates, reports or annexes of the
The lack of concordance between the data and evidence obtained in an appraisal.
Negative resistance or obstruction to the inspection work of the supervisory agencies
Failure to comply with the rules on independence established in the Internal Regulations of the
Negatively influencing the management of the appraisal company by means of influence exercised by an owner with a shareholding
The imposition of a serious infraction, within five years of the imposition of the same serious infraction and for the same
Not having an Internal Code of Conduct that establishes the incompatibilities of its directors and officers.
Accepting guidelines, instructions, recommendations, pressure or relevant information from any type of clients with the purpose of influencing the result of the valuation.
Absence or coverage of liability insurance less than

Failure to comply with any of these faults will result in the following penalties:

In the case of an employee, in accordance with Article 54 of the Workers’ Statute, it will be considered a breach of contractual good faith, as well as breach of trust in the performance of work, and the corresponding sanction will be initiated, including disciplinary dismissal, in accordance with the provisions of the legislation.
If the relationship with the defaulting party is merely mercantile, it shall be considered a cause for termination of the contract.
In the case of a member of the Board of Directors, the General Shareholders’ Meeting will be asked to dismiss him/her as such and disqualify him/her from holding administrative or management positions in the Company for a term not exceeding 10 years and/or a fine not exceeding €200,000.
If the conduct contrary to these regulations is carried out by a shareholder of the company, a General Shareholders’ Meeting will be called in order to analyze and agree on what is appropriate and, in any case, he/she will be excluded from the Board of Directors of the company, in the event that he/she is a member of the Board of Directors.

The following are considered serious misconduct:

The issuance of Appraisal Certificates that are not in conformity with the Appraisal Report, unless it is of a purely occasional or occasional nature.
Continued non-compliance with the principles, procedures, verifications and valuation instructions provided for in the applicable regulations and the internal rules of the Company.
The non-application of the principle of prudent valuation when the purposes of the valuation are some of those contemplated in Decree ECO/805/2003.
Any non-compliance with appraisal standards that may cause economic damage to third parties or to the person to whom the appraisal is rendered.
Failure to submit data that must be supplied to the Bank of Spain, CNMV or the Directorate General of Insurance and Pension Funds or failure to provide truthful information, when this hinders the assessment of the activity carried out by the appraisal company, or its financial or organizational situation, after the term granted for its correction has expired.
Lack of control of professional secrecy obligations and professional independence and incompatibilities that do not give rise to serious infringements.
To carry out pre-valuations or estimated valuations by providing information to the applicant, principal or mandated entity, in writing or by telephone, on request or without it, without due authorization from the
Failure to submit or respond to the Independence and Conflicts of Interest questionnaires in an appraisal.
When the Company repeatedly and continuously fails to meet the deadlines agreed with its customers without leaving a detailed justification in the Company’s computer systems or the failure to notify the

Failure to comply with any of these faults will result in the following penalties:

In the case of an employee, suspension of employment and salary for 2 to 10 days, and/or disqualification for a period not exceeding one year for promotion or higher position and/or temporary loss of category up to a maximum of six years.
If the relationship with the defaulting party is merely mercantile, its remuneration shall be suspended for a maximum of 60 working days and/or the assignment shall be temporarily suspended.
If the defaulting person is a Director, his or her remuneration shall be suspended for a maximum of 30 working days, while, if he or she is a member of the Board of Directors, the General Shareholders’ Meeting shall be requested to remove him or her from office and disqualify him or her from holding administrative or management positions in the Company for a period not exceeding 1 year, and/or a fine of not more than €1,000.
If the conduct contrary to these regulations is carried out by a shareholder of the company, a General Shareholders’ Meeting will be called in order to analyze and agree on what is appropriate and, in any case, he/she will be excluded from the Board of Directors of the company, in the event that he/she is a member of the Board of Directors.

The following shall be considered minor offenses:

When for a period of less than 3 months the Bank of Spain has not been requested to register the Company’s Related Professionals and they have signed on behalf of the company controls or validations of valuations carried out.
Failure on the part of the Commissioner in defense of the consumer to respond to a complaint or claim submitted to the Company through the channels established by law.
Failure to comply with the 6-month period between the issuance of an estimated appraisal and its corresponding definitive appraisal.
When, on an occasional but repeated basis, the Company fails to comply with the deadlines committed to with customers without leaving a detailed justification in the Company’s computer systems or the lack of communication to the Company.
When the conditions established in the ICR regarding the control of the standards set forth therein are not complied with.

Failure to comply with any of these faults will result in the following penalties:

In the case of an employee, the employee will be suspended from employment and salary for one day and a written warning will be issued.
If the relationship with the non-compliant party is merely commercial, the remuneration shall be suspended for a maximum of 15 working days and/or the commissioning of work shall be temporarily suspended.
If the non-compliant person is a Director, his or her remuneration shall be suspended for a maximum of 15 working days, while if the non-compliant person is a member of the Board of Directors, he or she shall be reprimanded internally and publicly within the company.
If the conduct contrary to these regulations is carried out by a shareholder of the company, an internal and public reprimand will be issued within the company.

The foregoing is without prejudice to any damages or other actions that may be required of those who incur personal liability for breach of the provisions of this IRC.

In addition, it should be noted that the penalties set forth in Law 2/1981, regulating the mortgage market, and Royal Legislative Decree 1/1995, of March 24, 1995, approving the revised text of the Workers’ Statute Law, will be applicable.

Details of the framework of the professional, financial or operational relationship

At present, the Company is part of the economic group whose parent company is the Company itself, a group that as of this date is comprised of the companies shown in the following table, a brief description of their corporate purpose and the percentage of control that the group has over them.

Identification of the person in charge of the appraisal service

The Head of the Appraisal Service is the person who holds the position of Technical Director of the Company.

Identification of the internal body approving the regulations

This IRC was approved by the Board of Directors of the Company at its meeting held on October 29, 2014.

Details of applicable incompatibilities

Appraisers may be exposed to situations that may impair their objectivity and independence of judgment. When these situations imply that the appraisee cannot reasonably maintain a position of independence and the objectivity of the appraisal is undermined, the appraisee must reject or abandon the assignment.

In particular, when the circumstances provided for in Articles 6 and 13 of Royal Decree 775/1997 (listed in the Annex) are met, those affected by these rules must reject or abandon the valuation assignment in question. In addition, the Company shall act with the utmost diligence to obtain from its directors, senior managers and professionals the appropriate information to ensure compliance with the incompatibilities referred to in the two aforementioned rules.

In addition to the incompatibilities provided by law:

The professionals through which a specific valuation assignment is channeled by a client may not participate in the valuation of the property to which the assignment refers.
Officers and employees engaged in commercial work may not act as
The directors of the Company with executive functions may not render their professional or labor services in the companies of the same group, or in those of any of its possible groups of influence, or assume executive functions in its administrative bodies, provided that;
1. The Company provides valuation services to such companies; and
2. These companies are regularly engaged in real estate development services or in the granting of loans related to the real estate sector.
3. In supervening cases, the executive director shall cease to render his services to such companies within three months of the occurrence of the
Neither the shareholders of appraisal companies that hold specific interests in the promotion or marketing of real estate, or in similar activities, nor their directors or employees, may intervene directly or indirectly in the appraisal of the properties in which they hold such interests, nor know the result of such appraisal before it is billed and To ensure this rule, the assignments of such properties shall be channeled exclusively through the Internal Audit Department of the Company.
The Company’s directors with executive functions shall inform the Company’s Board of Directors of any direct or indirect shareholding of 10% in any company belonging to the Company’s economic group or group of influence. In such cases, the Board shall decide whether to maintain the delegation of authority to the director, in particular with respect to its exercise with respect to such companies, whether to reduce its scope, or whether other measures are appropriate to avoid any bias in the services provided to such companies.
Relations, for valuation assignments, between the Company and the companies of its economic group or possible groups of influence, shall be channeled, without prejudice to the tasks corresponding to the Company’s executives, through the Company’s administrative and commercial departments. The employees or professionals technically involved in the valuation activity may not maintain contacts, in connection with an assignment made to the Company, with those employees or executives of the companies of the economic or influential groups that provide their services to the units related to the granting or marketing of the mortgage loans or credits, unless they are employees or executives with specific skills in the analysis or management of the risks to which the assignment refers.
Employees or professionals technically involved in the valuation activity may not maintain contacts, in connection with an assignment made to the Company, with those employees or managers of a banking institution or of a company engaged in the granting of loans or mortgage credits who are directly involved in this task, unless they are employees or managers with specific skills in the analysis or management of the risks to which the assignment relates.

The Company’s actions must be governed exclusively by technical criteria. by technical criteria

The Company considers that it is essential that its valuations and the valuations and other work of this nature provided by the professionals and other persons rendering their services to the Company enjoy the full confidence of the direct users of the valuations and of the other parties interested in them, and for this purpose the technical criterion is the sole criterion.

For this purpose, it assumes as essential that such work has been provided by the Company with appropriate technical expertise, professional skill and judgment, through a professional practice that is free from undue influence or bias.

Non-acceptance of any kind of influence by the economic group or the economic group or the directors or employees of the company. with the result of the valuation

In other circumstances it is impossible to define and prescribe all the other situations in which an appraiser may be exposed to factors that threaten his objectivity. Some of these threats are impossible or very difficult to mitigate; when this is the case, the valuator must also reject or abandon the assignment.

In other cases, potential threats to objectivity can be eliminated or mitigated by safeguards. These safeguards may include adequate disclosure of the threat to the parties concerned and obtaining their consent to proceed with the valuation in question if there are no satisfactory safeguards to eliminate or minimize a threat to objectivity, the valuator should reject or abandon the engagement.

In particular, neither the Company nor its professionals shall accept guidelines, instructions, recommendations, pressures or relevant information of any kind from clients, especially those coming from individuals or legal entities that are part of economic or influential groups or from their managers or employees, in connection with the appraisal activity and, particularly, with the result of the appraisal. Any information that could guide the result of the valuation is considered relevant, such as, in the case of valuations that may have effects with respect to third parties other than the client itself, the amount of the loan that could be granted for the acquisition or financing of the asset or the price agreed for the future sale and purchase of the asset.

Expression of secrecy obligations

The principle of confidentiality obliges all valuers (understood as the Company and other persons subject to compliance with this IRC) to comply with the rules on professional secrecy set forth in Article 11 of Royal Decree 775/1997 (See ANNEX) and, in general, to refrain from:

Disclose outside the company confidential information obtained as a result of the valuator’s own professional and business relationships, unless specific authorization is available or there is a legal or professional right or duty to disclose it; and
Use confidential information obtained as a result of professional and business relationships for your own benefit or that of a third party.

Code or set of rules of conduct to prevent conflicts of conflicts of interest with clients

In the event that the Company has any relationship with the customer that may involve a conflict of interest, the Company must reject the
The relationship with customers will be dealt with solely and exclusively from the Commercial Department, Business Development Department or from the company’s Management.
Once the conditions for the realization of any type of client have been agreed upon, it will be passed to the Process Department so that it can be transmitted with total objectivity to the Technical Department for its execution.
Once the appraisal has been carried out by the Technical Department, it will return to the Process Department to be sent to the client, without the involvement of the Commercial or Business Development Department.

Other contents

a) Description of the criteria or policies established to prevent the remuneration of the appraisal company’s directors or managers, as well as that of its employees, from being significantly linked to the results of the individuals or legal entities in its group of influence or of those companies in its economic group to which they provide services.

The remuneration of the Company’s executives, employees and professionals are not linked to those of companies other than the Company, and in particular are not linked to those of the individuals or legal entities of its group of influence or of those companies of its economic group to which services are rendered.

b) Ensure that the appraisal manager is totally external to the entity’s purchasing and commercial units, taking the necessary measures to separate the appraisal service from the organization’s commercial and operational services.

In order to avoid influences and conditioning by sales representatives in the technical execution of the appraisals, the company has a series of mechanisms that are detailed below:

Chinese walls between the Technical Department and the Commercial and Business Development Departments will work in different spaces.
Transmission of information. Any information that has to be transmitted from the commercial or business development department to the technical department or vice versa, will always be transmitted to the process and audit department, which will be in charge of filtering and purifying such information so that it does not influence the result of the valuations in any way.
Standard of contact with customers. The relationship with customers will be handled solely and exclusively from the commercial department, business development or from the company’s management. No technician, appraiser or validator will talk to clients to prevent them from conditioning the opinion of the appraisals.

Standards of ethical behavior of the appraisal technicians during the visit to the properties. In certain phases of the appraisal process it is impossible for the technician not to have contact with the client requesting the appraisal, for example during the visit, for this reason there are the following rules of ethical behavior that the appraiser must comply with:

The appraiser shall not have more distance from the client than is strictly necessary.
The appraiser will not respond to questions regarding the property or the real estate market that are asked by the contact person from the
The appraiser will not provide any opinion on the property or any matter affecting the appraisal during the
The appraiser should avoid any conversation that may influence the valuation.

c) Indication of whether the price of appraisals carried out for or on behalf of individuals or legal entities belonging to the economic or influence groups is established in the same way as for the rest of the appraisals.

The appraisal fees will not depend, in an essential manner, on the result of a previous appraisal or on the result of the appraisal itself. In any case, if fees are otherwise linked to the value of the asset, clients should be aware of this.

The fees for appraisals carried out for or on behalf of individuals or legal entities belonging to economic or influential groups are established in the same way as for the rest of the appraisals.

d) Details of the procedures established to prevent the transmission of any type of prior opinions on the appraisal value, such as estimates or indicative valuations that could enable arbitration in the selection of appraisal services or companies. Likewise, the procedures implemented to ensure that, in those cases in which, due to justified need, these prior appraisals must be performed, the appraisal company or service refrains, for a minimum period of six months, from performing the subsequent appraisal of the same assets, and leaves a written record of each of these cases and the reasons that justified it, in a specific file that is available to the Bank of Spain.

An appraiser must maintain confidentiality even in his or her social environment, and be vigilant not to inadvertently breach this obligation with co-workers, friends or family.

An appraiser must also maintain the confidentiality of information disclosed by potential clients.

An appraiser must maintain the confidentiality of information within the company or business organization.

The need to comply with the principle of confidentiality continues even after the relationship between an appraiser and his or her client or employer has ended. When a professional changes jobs or acquires a new client, the appraiser is entitled to use his or her previous experience. However, the appraiser may not use or disclose any confidential information acquired or received as a result of a prior business or professional relationship.

The Company shall take the appropriate measures to ensure that the personnel in charge of the Company respects due confidentiality.

The following are examples of circumstances in which a valuator may be required to disclose confidential information or where disclosure is appropriate:

The disclosure is permitted by law or is authorized by the customer or employer.

Disclosure is required by law, as a consequence, for example, of:

The production of documents or other presentation of evidence in legal proceedings;
Disclosure to the competent public authorities, especially the supervisor;
Disclosure to the authorities responsible for sanctioning infractions

There may also be a professional duty or right to disclose, where not prohibited by law, for example:

To comply with the confidential quality review of a professional organization or to meet the investigation that may be carried out by such an organization, provided that in both cases the confidentiality of that process is assured;
To protect the professional interests of an appraiser in the context of a legal proceeding, or to comply with technical standards and ethical requirements

In deciding whether to disclose confidential information, relevant factors to consider include the following:

If the interests of all parties, including those of third parties, may be affected or affected by the
If all information is known or relevant when the situation involves unsupported facts or conclusions, or incomplete information, professional judgment will be used to determine the type of disclosure that can be made, in its
The type of communication that is expected and to whom it is addressed
Whether the parties to whom the communication is addressed are the addressees

The obligation of professional secrecy does not apply to data obtained in the course of an appraisal that does not permit the identification of the client or the appraised asset, in particular data sent to the authorities (currently to the Ministry of Public Works or the INE) for the preparation of aggregate data, nor, therefore, to aggregate data that may be disclosed for statistical or research purposes.

Integrity implies fair and truthful dealing, so that the appraiser must never act in a deceitful or fraudulent manner. Thus, you should not prepare or disclose a valuation or any other communication about a valuation if you believe that:

Contains statements or information that are materially false or misleading, or that are made recklessly or without reasonable justification.
Omits or hides relevant information that should be included in the valuation.

If the valuator becomes aware that he/she has been associated with such information, he/she should take immediate steps to disassociate him/herself from that information, for example, by issuing a modification of that valuation or report.

Nor should you use false or misleading statements, or claim to have qualifications or capabilities that you lack, for the purpose of obtaining an appraisal or other assignment.

Neither the Company nor the professionals rendering valuation services to it shall give clients, except for fully justified necessity, any kind of prior opinions on the appraisal value of a specific asset, such as estimates or indicative valuations, which could enable arbitration in the selection of a valuator.

This will not affect:

To appraisals in the strict sense, i.e. those subject to generally accepted standards (ECO Order; RICS; TEGOVA), nor to any contacts that may be established with a client in the context of an assignment of this nature.
To the individual valuations of an automatic nature offered by internet (on line), which, for this purpose, shall include an indication that it is merely an indicative estimate that does not commit the company in the event of a subsequent formal order.
Statistical valuations framed within a massive portfolio;
To the previous valuations framed in a consultancy on a certain project or real estate operation.
To general estimates of prices in a given territorial or functional environment.

The prohibition affects any manner of giving an opinion (whether in writing or by telephone; commissioned or not) provided that it is made on the plausibility (subject to the judgment of a sufficiently diligent expert appraiser) that it can be used to arbitrate on the value of the property in question.

In order to ensure compliance with the preceding point, the Company shall keep a record of previous opinions on the value of an asset that it may have provided to a client. This record shall include the reasons that have justified the need for the issuance of this indicative valuation.

The Register shall be kept by the internal audit and its contents shall be regularly reported to the Board of Directors.

In such cases, the Company will reject any appraisal order on that property within six months of the issuance of the indicative valuation.

e) Description of the policies established for the purpose of rejecting assignments for which the company lacks the necessary qualifications, either because it does not have specialized professionals or the necessary technical means, or because of a lack of recent experience either in the valuation of assets of the same type or in the geographical area where the assets to be valued are located.

The Company will act at all times with respect to any valuation assignment:

Having adequate knowledge of the market in which the asset to be appraised is marketed, in accordance with the provisions of the second additional provision of Order 805/2003,
Ensuring uniform compliance with applicable valuation standards as required by the above provision; and
Maintaining the remaining professional knowledge and skills to the extent necessary to ensure that customers receive a diligent and professional service
Continuously evaluating the performance of the professionals who provide appraisal services, to which end they will keep for each one, not only the personal file referred to in Article 12 1 and 2 of RD 775/1997 (See ANNEX), but one that reflects their knowledge and experience, as well as their knowledge and experience.
Assuming the professional standards on technical and human resources approved in July 2013, the Spanish Association for the Analysis of

A competent professional service requires the exercise of the technical autonomy proper to all practitioners in the application of knowledge and professional skills to that service.

Maintaining professional competence requires a continuous awareness and understanding of the relevance of technical, professional and business developments. Continuous professional development enables an appraiser to develop and maintain his or her skills to perform competently in a professional environment.

Diligence includes the responsibility to act in accordance with the requirements of an assignment, prudently, thoroughly and in a timely manner.

An appraiser shall take reasonable steps to ensure that persons working under his authority or assisting him have adequate professional ability and training, and that they are always under appropriate supervision or control, regardless of the scope or extent of their work.

An appraiser who does not have adequate knowledge and experience to competently carry out the appraisal in question must reject it.

The appraiser should not rely on party information without first confirming it, unless the appraiser establishes and discloses that such party information constitutes a restriction that conditions the report. The same rule applies to the acceptance of assumptions, although in this case, in addition, the appraiser should not accept assumptions that are unlikely to be fulfilled within a reasonable time.

All valuation reports must provide a reasoned justification and disclose in the simplest and most comprehensible manner the assumptions and criteria on which the valuation is based.

f) Indication of the procedures generally used to allocate appraisals, specifying in particular whether such allocation is centralized and, Likewise, indication of whether there is any difference between the aforementioned general procedures and those specifically used for the allocation of orders from individuals or legal entities of the economic or influential groups, with an expression, if applicable, of the existing differences.

The assignment of the appraisals will be randomized among the technicians who are qualified for the execution of the work and can meet the operational requirements of the job in terms of time and location.

The selection of qualified technicians will be made through the technical classification provided by the technical department.

The evaluation of this technical classification will be carried out by the Company’s technical manager on a monthly basis.

Once the technician has been randomly assigned within the selection of technically and operationally qualified technicians, the existence of incompatibilities or possible conflicts of interest that may exist will be verified.

In the event of incompatibility or conflict, that technician will be discarded for that job and will be randomly reassigned.

If no qualified technician is available, the job will be rejected.

g) Details of the stipulations established to prevent shareholders of appraisal companies that have specific interests in the promotion or marketing of real estate, or in similar activities, from intervening directly or indirectly in the appraisal of such property, and that they know the result of such appraisal before it is billed; and

Neither the shareholders of appraisal companies that have specific interests in the promotion or marketing of real estate, or in analogous activities, nor their directors or employees, may intervene directly or indirectly in the appraisal of the properties in which they have such interests, nor know the result of such appraisal before it is invoiced and delivered. To ensure this rule, orders for such goods will be channeled exclusively through the process department and supervised by the Internal Audit department.

h) Description of the procedure established for the systematic monitoring of the degree of compliance with the regulations, as well as for the assessment of the effectiveness of the Board of Directors shall periodically, and at least once every 3 years, commission an audit of the procedures aimed at ensuring compliance with the provisions of the IRC and, in particular, the effectiveness of this Regulation in preserving the independence of the Board of Directors and the effectiveness of the Board of Directors in ensuring compliance with the provisions of the IRC.

i) Indication that the internal controls and audits of the commercial and operational areas of the economic group to which the appraisal company belongs, or of the credit institution with its own appraisal service, shall be carried out independently from those carried out on the appraisal company or service.

The internal controls and audits of the commercial and operational areas of the economic group to which the appraisal company with its own appraisal service belongs shall be carried out independently from those carried out on the appraisal company or service.

j) In the event that shareholders or directors of the appraisal company, or other officers of the appraisal company or of the appraisal service, render services as professional appraisers, related or not, for the referred company or service, description of the respective

None of the shareholders or directors of the appraisal company, nor other officers of the appraisal company shall render services as professional appraisers.

Annex

PARTICULARS OF ROYAL DECREE 775/1997, OF MAY 30, 1997, ON THE LEGAL REGIME FOR THE APPROVAL OF APPRAISAL SERVICES AND APPRAISAL COMPANIES:

ARTICLE 6 – INCOMPATIBILITIES OF APPRAISAL COMPANIES

Without prejudice to the provisions of other specific rules, appraisal companies may not appraise assets, companies or estates owned by individuals or legal entities with which they cannot reasonably maintain a position of independence to the detriment of the objectivity of the appraisal.

In particular, they must refrain from valuing property, companies or assets owned:

From the appraisal company itself or from companies belonging to the same appraisal company
Of its shareholders, if they directly or indirectly participate in its capital stock or have, by virtue of agreements entered into with other shareholders, voting rights in a percentage higher than 10% of its capital stock, or if they have, by virtue of agreements entered into with other shareholders, voting rights in a percentage higher than 10% of its capital stock.
Of its directors, officers or
Of the relatives of the aforementioned persons up to the second degree of consanguinity or marriage, or
From collective investment institutions in which they have investments or whose manager or depositary belongs to the same group as the appraisal company.
Pension funds in which they have investments or whose management company belongs to the same group as the appraisal company.

ARTICLE 10 – INCOMPATIBILITIES OF THE APPRAISAL SERVICES

Without prejudice to the provisions of other specific rules, appraisal services may not appraise property owned by natural or legal persons with whom they cannot reasonably maintain a position of independence that undermines the objectivity of the appraisal.

In particular, they shall refrain from valuing property:

Of the credit institution to which they belong or of companies that form a group with it.
Of the shareholders of the credit institution to which the appraisal service belongs, provided that they directly or indirectly participate in its capital stock or have voting rights in a percentage of more than 1 percent of its capital stock.
Of the administrators, managers or

Of the relatives up to the second degree of consanguinity or affinity of the persons mentioned in the two letters above.

ARTICLE 11- SECRECY OBLIGATIONS

Approved appraisal companies and credit institutions with approved appraisal services shall be especially subject to compliance with the duties of professional secrecy. By virtue thereof, they may not disclose to third parties other than their customers:

The information entrusted to them in connection with the application for the appraisal.

The information that refers to the personal or economic circumstances regarding the use or exploitation to which the object of the valuation is dedicated.

The result of the appraisal.

Notwithstanding the provisions of the preceding number, as well as the provisions of the regulations regarding the data to be included in the appraisal report, appraisal companies and services may disclose such data:

To the entities that have been mandated by their clients for the order or delivery of the valuation.

To the owners of the assets, companies or patrimony subject to valuation.

To the Bank of Spain, the National Securities Market Commission and the Directorate General of Insurance for the exercise of their supervisory functions and for the preparation and publication of statistics related to their activities.

The administrators, directors and similar of the appraisal companies and credit institutions with appraisal services, the professionals who perform appraisal activities for them, as well as the rest of the contracted personnel, may not use for their own benefit or disclose to third parties the information that they know as a consequence of the exercise of their activity by virtue of the contract entered into with said appraisal companies and institutions with appraisal services.

ARTICLE 12 – OBLIGATIONS AND RESPONSIBILITIES

Approved appraisal companies and credit institutions with approved appraisal services shall:

To have an internal registry in which they will have to register the professionals they have to provide appraisal services. This record shall contain, at least, the following data:
1. Identification of the
2. Accreditation of your qualifications and professional relationship with the company
3. Professional background that accredits their experience in the appraisal activity.

File with the Bank of Spain:
1. Certified copy of the title or document of registration in the corresponding professional association.
2. History of those mentioned
3. Documentary evidence of the professional relationship between the entity and the said
4. The cancellations of the same, as well as their replacements, with documents

ARTICLE 13.- INCOMPATIBILITIES OF PROFESSIONALS

Without prejudice to the provisions of other specific rules, professionals performing appraisal activities for approved appraisal companies and in the approved appraisal services of credit institutions may not appraise goods, companies or assets owned by persons with whom the professional cannot reasonably maintain a position of independence, to the detriment of the objectivity of the appraisal.

In particular, they must abstain from participating in the valuations of the following assets, companies or estates:

Those in which they are intervening professionally through the formulation of a project or through the direction or collaboration in the direction of the

Those belonging to the professional himself/herself, to his/her relatives up to the second degree of consanguinity or affinity or to companies in which such persons exercise the

Those owned by real estate investment trusts in which any of the persons mentioned in the preceding paragraph hold investments

Related professionals may not provide their services as appraisers to any credit institution or appraisal company other than the one to which they belong, except for those assigned to appraisal services, who may appraise assets for companies belonging to the same group as the entity that owns such appraisal services.