I. Pro Bono Program of Uribe Henao Abogados (the “Firm”)

1.1 The Firm’s Pro Bono Commitment

We aim to provide low-income populations with access to the highest quality legal services. We seek to contribute to the growth and construction of our country through the practice of law and the formalization of socially responsible projects.

1.2 Objectives of the Pro Bono Program

• To channel the Firm’s legal knowledge to provide our legal services to the community.

• To promote Pro Bono work within the Firm to generate a positive social impact.

• To raise awareness among the Firm’s attorneys to provide their legal services recurrently and free of charge through the Pro Bono Foundation (the “Foundation”).

II. Concept of Pro Bono Work

The Firm understands Pro Bono work as the legal services provided by its attorneys free of charge to the most vulnerable individuals and communities in the country, as well as to non-profit entities and those pursuing a social or humanitarian purpose.

III. Description of the Pro Bono Program

3.1 Principles of Pro Bono Work

The Firm recognizes the existence of the following basic guidelines that will serve as the basis for undertaking any Pro Bono case:

a. Gratuitousness: Pro Bono work carried out by the Firm is free of charge, and clients cannot be asked to pay fees or salaries for the legal assistance provided; notwithstanding the foregoing, Pro Bono clients must cover the additional expenses arising from their case.

b. Equal Treatment: Pro Bono clients will be served under the same conditions as paying clients.

c. Legal Services: Pro Bono work may only be carried out by attorneys on legal matters; therefore, support provided by other areas of knowledge will not be considered as such. Notwithstanding the foregoing, other employees may also participate in Pro Bono cases, and may log the hours they dedicate to them in the system established by the Firm for this purpose.

d. Voluntariness: Attorneys associated with the Firm will freely decide whether to take the Pro Bono cases presented to them; this is without prejudice to the different incentives established by the Firm for this purpose.

e. Institutionalization: The intake of Pro Bono cases will be governed by the provisions of this Pro Bono Policy Manual (the “Manual”) and will be managed by the individuals designated for this purpose.

3.2 Beneficiaries of Pro Bono Work

The following may be beneficiaries of the Pro Bono work carried out by the Firm:

a. Natural Persons: Individuals belonging to stratum 1, 2, and 3 who do not have the resources to pay for an attorney’s services; however, the Firm may exceptionally take cases of individuals who do not belong to these socioeconomic groups when their economic situation is evidently very serious and they have several dependents.

b. Legal Entities: Non-profit organizations that provide services to vulnerable communities and do not have the resources to pay for an attorney’s services. Likewise, requests presented by micro-enterprises may be handled when their members are part of vulnerable communities.

c. Communities: Groups of citizens, members of a vulnerable community, who group together to solve a social problem.

3.3 Forms of Assistance

The Firm’s member attorneys may assist Pro Bono clients in the following ways:

a. Legal Advisory: The attorney will guide the Pro Bono client in carrying out administrative, notarial, or registry procedures where acting through legal counsel is not required. This category also includes ongoing and prolonged advisory services provided to non-profit entities, as well as various training sessions conducted by the Firm.

b. Preparation of Legal Opinions: The attorney will draft a legal document, resolving the legal queries posed by the client.

c. Legal Representation: The attorney will represent the Pro Bono client in potential litigation or an ongoing judicial process. This form of assistance implies granting a power of attorney to the professional and their appearance before judicial and/or administrative bodies, as the case may be.

3.4 Lines of Action

The following lines of action are the forms of Pro Bono work available at the Firm, in which attorneys and other associated staff may participate:

a. Individual Cases: The Firm understands an individual case as any request for free legal assistance presented by a natural or legal person that addresses an unmet legal need specific to the applicant.

b. Collective Impact Cases: The Firm understands a collective impact case as those requests for free legal assistance presented by a natural person, legal entity, or community, which attempt to resolve a collective-level problem, through the following forms:

* Free Legal Education Workshops: This line of action consists of conducting workshops and seminars on legal topics of interest and social impact, aimed at vulnerable populations or workers in social organizations.

* Legal Clinics: In this type of request, a group of attorneys will travel to the community’s settlement area to be impacted, and participate in the analysis, filtering, and handling of requests for legal assistance through personalized interviews.

* Legal Research: Attorneys will participate in the design of strategies with structural impact. This line includes work on draft legislation, regulatory developments, among others. It also includes legal research on a socially relevant topic, conducted by attorneys of the Pro Bono Foundation (the “Foundation”) to support a social organization, which seeks to establish the normative and jurisprudential framework of the specific matter in order to impact public policy.

* Community Litigation: Addressing collective needs. This seeks rulings from authorities that benefit a large population group, expanding legal protection for vulnerable individuals and groups.

* Projects: Advisory to non-profit legal entities for the execution of projects related to their corporate purpose, where the direct beneficiaries are the vulnerable population they serve.

* Strategic Litigation: Through this line of Pro Bono work, the aim is to generate broad social changes that contribute to transforming societal structures, by choosing a particular case whose characteristics and relevance are such that it manages to impact the protection of the rights of citizens in identical or similar conditions.

* Service Cycle: Through this model, a community is provided with comprehensive advisory that includes training on rights and duties, and the completion of specific projects.

The Firm will refrain from taking cases that are outside its expertise.

IV. Internal Structure of Pro Bono Work

The following will be the main individuals responsible for Pro Bono work within the Firm:

4.1 Pro Bono Partner:

The Pro Bono Partner is the main person responsible for Pro Bono work within the Firm. This may be the managing partner or any other person with the same rank within the Firm. The main characteristics are described below:

i. Appointment: The Pro Bono Partner will be appointed in a meeting held by all the Firm’s partners. Their appointment will be formalized through an acceptance letter, which must be sent to the Foundation indicating their name and general contact information.

ii. Functions:

a) Lead the Committee meetings and activities.

b) Supervise, along with the Committee, the social responsibility program within the Firm.

c) Attend and participate in the General Assembly of the Pro Bono Foundation.

d) If appointed as a member of the Foundation’s Board of Directors, attend and participate in the quarterly meetings.

e) Approve, if applicable, extraordinary expenses in Pro Bono matters.

f) Keep the Foundation and other Clearing Houses informed of any modification to their functions or resignation from the position.

g) Participate in the annual evaluation of the Pro Bono program.

4.2 Pro Bono Committee:

The Pro Bono Committee (the “Committee”) is the highest governing body of the Pro Bono program within the Firm, with the following members and functions:

i. Members:

a) Pro Bono Partner or another designated partner.

b) Pro Bono Coordinator(s).

ii. Functions:

a) Develop and ensure the proper functioning of the Pro Bono program.

b) Approve the internally developed Manual.

c) Make any required decisions regarding new matters in the Pro Bono field.

d) Define the mechanisms to promote and recognize Pro Bono work.

e) Appoint the Firm’s Pro Bono Coordinator.

f) Assist the Coordinator in the planning and execution of social projects.

g) Conduct an annual evaluation of the Firm’s Pro Bono performance.

h) Keep the Foundation informed of any modification in the internal composition of its members.

i) Nominate the Pro Bono Attorney of the Year for the Pro Bono of the Year awards.

j) Approve the annual contribution given to the Foundation.

k) Approve the Firm’s participation in the various academic, cultural, and sports activities held annually by the Foundation or other Clearing Houses.

l) Define the policy for recognizing hours within the Firm’s billing system.

m) Take the necessary measures to resume cases that are inactive.

n) Take sanctionary measures against attorneys who commit serious faults in Pro Bono cases.

V. Pro Bono Case Management and Follow-up

5.1 Case Intake

For Pro Bono case intake, a person from the Foundation will periodically send attorneys the case bulletin, which describes the facts and scope of the request. Attorneys must also follow these steps:

i. Review the Pro Bono case bulletin and identify a case of interest.

ii. Contact the Pro Bono Coordinator and inform them of the interest in taking a case.

iii. The Pro Bono Coordinator will check for a possible conflict of interest in taking the case.

iv. Subsequently, the Pro Bono Coordinator will proceed to assign the case on the Foundation’s platform and on the Firm’s internal one.

v. Next, the Pro Bono attorney will contact the Pro Bono client and coordinate the first meeting, which must be held no later than 8 days following the case intake.

vi. They will then draft the engagement letter.

vii. Finally, they will meet with the Pro Bono client to explain the scope of the advisory and proceed with signing the corresponding engagement letter.

Likewise, the Firm may autonomously take Pro Bono cases that have come to it through other persons and/or organizations that are not part of the Foundation, but which are subsequently linked to it. Thus, the following steps must be followed:

i. The attorney who learns of the possible Pro Bono case must communicate it to the Pro Bono Partner or Coordinator.

ii. The Committee will decide on the case’s viability and inform the responsible attorney.

iii. A member of the Committee will communicate with the Foundation to analyze the case’s viability through the Foundation.

iv. If viable, the Pro Bono attorney must contact the Pro Bono client to coordinate their entry into the Foundation and, subsequently, assign the case.

v. The Pro Bono attorney must coordinate the first meeting with the Pro Bono client, which must be held no later than 8 days following the case intake.

vi. The Pro Bono client and attorney will meet to explain the scope of the advisory and proceed with signing the corresponding engagement letter.

5.2 Signing of the Engagement Letter

The engagement letter is the contract between the Pro Bono attorney and the Pro Bono client, which determines the scope of the legal assistance, limiting the attorney’s liability to the client.

This document must be signed by the Pro Bono client and the Pro Bono attorney and must be uploaded to the corresponding platforms. Furthermore, if another Firm employee who is not an attorney is involved in the case, their signature must also be included in the engagement letter, as well as the scope of the support they are willing to provide.

5.3 Logging of Updates and Hours

Attorneys who take Pro Bono cases must log the hours they dedicate to them on the platforms indicated to them by the Pro Bono Coordinator for this purpose.

5.4 Follow-up and Supervision of Pro Bono Cases

All Pro Bono cases handled by the Firm will be under the supervision of the Pro Bono Partner and Coordinator.

Attorneys are obligated to report, when required, the status of the free legal assistance requests they are handling.

Periodically, members of the Foundation or other Clearing Houses will conduct performance evaluations of the attorneys in Pro Bono cases, as well as the satisfaction level of Pro Bono clients.

In the event that the attorney does not respond to information requests made by any member of the Committee, Partner, or Pro Bono Coordinator, or has not diligently handled the Pro Bono client, the case will be withdrawn from them and assigned to another attorney at the Firm.

If this situation arises, the Pro Bono Coordinators will inform the Pro Bono Partner of their lack of diligence and, additionally, the billing department, so that they remove the hours reported for the abandoned case and they are not taken into account in their billing.

5.5 Change of Attorney

Pro Bono cases must be completed by the attorney who initially takes them; however, if the associate resigns from the Firm, they may find an attorney to replace them within the Firm. Thus, for the substitution, the following procedure must be carried out:

i. Before leaving the Firm, the attorney must find another professional to replace them on the Pro Bono case, preferably from their same work team.

ii. Likewise, they must inform the Coordinators of their departure from the Firm and provide them with a report detailing the actions taken and difficulties encountered with the Pro Bono case.

iii. If they find an associate to replace them, they must carry out the corresponding case handover and report this situation in the Foundation’s or other Clearing Houses’ system, as well as in the Firm’s system.

iv. If they do not find a replacement, they must inform the Coordinator of this situation, who will proceed to send an email to all attorneys in the Firm to find a volunteer to take on the request.

v. In the event that the Coordinators do not find a volunteer after the first email, they will send an email to the heads of each of the Firm’s areas to help them place the case.

vi. If a volunteer attorney is still not found, the case will be assigned by lottery to any of the attorneys associated with the Firm.

5.6 Termination of Pro Bono Cases

Pro Bono cases are terminated when the object of the engagement letter is fulfilled (closing) or due to an abnormal situation, either on the part of the client or the attorney, which prevents the request for free legal assistance from being satisfactorily met (withdrawal).

To proceed with the formal termination of the case, it is essential that the Pro Bono attorney handling it drafts the corresponding termination letter, which will vary depending on whether it is a closing or withdrawal situation.

The letter must be signed by the Pro Bono attorney and the Pro Bono client or, failing that, signed only by the Pro Bono attorney when the document is sent to the client’s residence via email or WhatsApp messaging.

Once the letter meets the specified requirements, it must, along with the proof of sending, be scanned and uploaded to the Firm’s system, the Foundation’s, or other allied organizations’, so that they may authorize or certify the case’s completion. Furthermore, the following are specified as grounds for closing:

i. Success.

ii. Death of the applicant.

iii. Immediate resolution of the request.

iv. Other.

Secondly, the following are specified as grounds for withdrawal:

i. By the user:

a) Dissatisfaction with the service.

b) Lack of suitable attention from the attorney.

c) Disappearance of the legal need.

d) Voluntary waiver of legal assistance.

e) Tacit withdrawal.

f) Has another attorney.

g) Other.

ii. By the attorney:

a) Application of the termination grounds in the engagement letter.

b) The case became legally unviable.

c) Client has another attorney.

d) Impossibility of contacting the client.

e) Other.

VI. Evaluation of Pro Bono Work

The Coordinators, or the member established by the Committee, will evaluate the satisfaction level of Pro Bono clients annually using data provided by the Foundation or other organizations.

Likewise, annual interviews will be conducted with volunteer attorneys to determine the difficulties or best practices encountered when handling a Pro Bono case, where they will be asked about what type of cases they would be willing to take.

Their responses will be shared internally.

Furthermore, the Committee members will conduct a general evaluation of the Pro Bono work carried out by the Firm, taking into account the following points:

i. Number of cases handled compared to previous years.

ii. Difficulties and best practices encountered in handling Pro Bono cases.

iii. Analysis of reports, diagnostics, or other documents presented by other allied organizations.

iv. Highlighted individual and collective impact cases.

v. Results of interviews with Pro Bono clients and Pro Bono attorneys.

vi. Performance projection for the year following the evaluation.

Once the evaluation is finished, the Committee members will provide the corresponding comments and suggestions to the other attorneys in the Firm.

VII. Liability

Attorneys who take a Pro Bono case are responsible for handling them with high standards of quality. The Firm and its attorneys will not assume any type of financial liability for the execution of Pro Bono assistance.

The liability regime applicable to the Firm’s attorneys is that contained in the Attorney’s Disciplinary Code.

VIII. Incentives for Pro Bono Work

i. The attorney who takes the most Pro Bono cases in the Firm will be rewarded with one day off.

ii. Attorneys who take three or more cases in the same year will be rewarded with half a day off.

iii. Litigation cases: Attorneys who take and close two or more litigation cases will have half a day off, which will be earned at the time of closing.

Days off will be arranged in mutual agreement with their manager.