Team size: 15

How does it address the management of legal aspects during periods of instability or crisis, and how is its legal strategy aligned with the overall business strategy to guarantee the organisation’s resilience?

The management of legal aspects during periods of instability or crisis, and the alignment with overall business strategy, is addressed through a comprehensive approach that prioritises portfolio quality, risk management, and strict regulatory compliance.

The Company has demonstrated resilience, having successfully navigated challenges in 2024 and 2025, including continuous inflationary pressures and changing market conditions.

Strategic Alignment and Business Resilience: The legal and compliance strategy is directly aligned with the Company’s strategic vision to prioritise portfolio quality and profitability over its size to build solid foundations for growth and consolidate our position in the microcredit market.

A) Focus on Risk Management and Collection:

i. The Company maintains a culture of sound risk management as a fundamental part of its strategy.
ii. Robust operational and credit origination policies have been implemented through digital solutions, utilising phased analysis processes and decision engines that determine requirements for the customer based on their risk profile.
iii. Legal management is supported by an advanced collection process that combines remote and in-person activities, focusing on early delinquency to reduce the generation of reserves. The untimely payment of a loan can negatively impact the debtor’s future capacity to obtain or renew credit.
iv. In the event of litigation considered high risk or high contingency, the Company establishes the necessary reserves.

B) Regulatory Framework and Mitigation of Legal Risks:

i. The Company is subject to supervision by the Comisión Nacional Bancaria y de Valores (CNBV) in two aspects: (i) as a public company and (ii) as a financial institution (only regarding AML/FT), by CONDUSEF (regarding transparency and user defence) and Banco de México.
ii. In AML/FT matters, policies and procedures are in place to prevent and detect illicit operations, and the Company has a Communication and Control Committee for these risks.
iii. Continuous regulatory compliance is monitored every day.
iv. Our geographic diversification (operating in Mexico and the U.S.) mitigates the risk of regional economic slowdowns. Nevertheless, political risks, economic risks, and regulations in Mexico and the United States (including federal, state, and local laws in the U.S.) can adversely affect operations.

What are the main cases or transactions you have recently participated in?

As Corporate Legal and Regulatory Director, I have recently participated in various financial and corporate transactions, primarily during the last years, focusing on debt restructuring, corporate control reorganisation, and key financing management.

The most relevant transactions were:

A) International Debt Restructuring (Notes):

i. Bond Exchange and Amortisation: We executed a successful exchange offer of the outstanding 2024 bond for a new bond with maturity in 2028. This exchange achieved a high acceptance rate of 64%. Subsequently, we completed a total anticipated amortisation of the remaining 2024 bond. This process was critical for strengthening the Company’s structure and balance.

The resulting structure of our current debt, as of 31 December 2024, includes Ps. 1,597 million of callable bonds issued in US dollars with a March 2028 maturity.

ii. In May 2025, the Company made a new issuance of debt up to US$100,000.00 due by 2028.

B) Relevant Bank Credit Lines:

i. HSBC México: On 24 November 2023, the Company and one of its subsidiaries (Apoyo Económico Familiar) entered into a revolving credit facility agreement for Ps. 1,400.0 million (for working capital and corporate uses) with a 36-month term. Concurrently, they celebrated an irrevocable guarantee, administration, and payment source trust.

In July 2023, we created an irrevocable master trust agreement for administration and source of payment with HSBC as trustee.

The primary purpose of this trust is to implement a mechanism to facilitate the reception, administration, reconciliation, and periodic dispersion of payments that the Company and Apoyo Económico Familiar receive from their clients, derived from the credit agreements those clients execute with them.

ii. Nafinsa: On 4 October 2024, FINDEP increased its credit line limit to Ps. 1,050.0 million.

What measures has your company taken to embed sustainability practices into its core business operations, and how does the role of the general counsel contribute to driving and ensuring sustainable practices within the company?

Our company integrates sustainability by focusing primarily on the creation of social value.

Sustainability Measures (Social Value):

The main objective of our business is to grant unsecured loans to individuals in the low-income segments of the formal and informal economy in Mexico and the United States. By doing this, we fulfil a key microfinance goal: offering an opportunity to individuals who would otherwise have no access, or limited access, to financial institutions so that they can develop a long-term relationship with the Company and build a credit history.

Microfinance in general is considered beneficial for low-income segments, allowing families to transition from daily survival to long-term economic planning, reducing vulnerability and increasing income and savings. These services allow low-income individuals to face liquidity problems, take advantage of economic opportunities, and, in the long term, emerge from poverty.

In addition to social value, we seek the creation of economic value for our customers and shareholders.

Regarding environmental practices: It is important to note that, due to the nature of our business, the Company does not consider its operation to involve any environmental risk. Therefore, we currently do not have any specific environmental policies, nor do we intend to install an environmental management system. The Company’s operation does not have a relevant, current, or potential impact resulting from climate change.

Contribution of the Corporate Legal Director’s Role:

As the Corporate Director of Legal and Regulatory Affairs, my role is crucial for ensuring sustainability from the perspective of legality and compliance. This involves:

a) Ensuring Regulatory Compliance: We ensure compliance with applicable legislation, including the Securities Market Law (LMV), provisions of the CNBV, the National Commission for the Protection and Defence of Users of Financial Services (Condusef) and Banco de México.

b) Transparency and Customer Protection: The law requires us to guarantee the transparency and effectiveness of the systems used and the protection of users.

c) Prevention of Legal and Financial Risks: I am responsible for regulatory compliance regarding AML/FT. The Company has a Compliance Officer certified by the CNBV and a Communication and Control Committee, strengthening the integrity of our operations. The CNBV has the power to supervise the Company specifically in relation to AML/FT. I personally hold a certification in this matter issued by CNBV.

Which legal tech organisations or products are helping you in your role?

In my role as Corporate Director of Legal and Regulatory Affairs, the legal and compliance function relies heavily on the Company’s advanced Information Technology (IT) infrastructure and robust governance systems.

The Company has invested significant resources in IT, developing internal systems tailored to our specific needs. While specific “LegalTech” brands are not named, the infrastructure provides essential tools for governance and compliance:

a) Risk Management and Regulatory Systems: We utilise advanced IT systems and programmes related to our information and risk management policies. We have implemented processes based on Artificial Intelligence (AI) focusing on risk management, client profiling, and contact management. These AI-based processes provide us with a tactical advantage across all our business processes.

b) Data Management and Security: Our systems manage the extraction, transformation, and integration of operational data into the Data Lake (Big Data) for decision-making. We maintain an electronic record of all our credits. For data privacy, the Company stores multiple data elements encrypted in its database systems.

c) Governance and Control: We rely on formal corporate structures for oversight, including the Integral Risk Management Committee and the Communication and Control Committee for the prevention of money laundering and terrorism financing (AML/FT), both of which meet monthly.

d) Operational Efficiency and Field Tools (relevant to Compliance/Collections): Our latest-generation platform, based on microservices, leverages a multi-cloud approach and other modern technologies. We utilise sophisticated software for monitoring customer payments and taking appropriate actions on overdue accounts. Our field agents and verification teams are equipped with smartphones running corporate software which includes geolocation features to verify addresses. Furthermore, we have systems that detect and alert deviations from negotiation policies by collectors, supervisors, and managers, ensuring greater efficiency in our processes.