**Exhibit
      14.1.**











**Code
      of Ethics**









**UPDATED:** **April,
      2008**


Approved
      by the Nomination and Compensation Committee and by the Board of Directors
      in
      its April 14, 2008 meeting, as stated in the corresponding
      minutes.





**INTRODUCTION**





The
      set
      of ethical principles adopted by the Latin American Export Bank (Banco
      Latinoamericano de Exportaciones - “Bladex”) shall be a guideline for its Board
      of Directors and team of employees in the independent performance of business
      transactions as well as for their personal and interpersonal conduct, both
      within the Bank as well as without.





Those
      ethical principles shall also be for ensuring and enhancing the image of an
      Institution that can be relied upon because of its solid principles and
      values.





Bladex,
      as a supranational institution, with a shareholding structure representing
      the
      public and private sectors, has to deal with a series of different interests
      that need to be regarded with guidelines for carrying out its business, at
      all
      times adhering to the principles of honesty, responsibility and
      integrity.





The
      principles set forth hereunder have been adopted as the Code of Ethics,
      governing all members of the Board of Directors as well as all other Bladex
      employees.





The
      Board
      of Directors is responsible, together with the Management Committee, for
      promoting the highest integrity and ethical standards, as well as for
      establishing an organizational culture showing and emphasizing to all of the
      staff the importance of each one at the Bank.





All
      members of the Bladex team shall avoid any situation that might cause a conflict
      of interest between the Bank, its Clients, Shareholders, Directors, Members
      of
      the Advisory Board, Suppliers and Employees. At the same time, each supervisor
      shall guarantee that his/her subordinates participate exclusively in those
      assignments and tasks for which they have the required knowledge, abilities
      and
      expertise.


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**1.**  **Objectives**


Bladex
      Code of Ethics has the following objectives:





·
            To
                act as a guideline for establishing relationships, both within as
                well as
                without theBank,
                based on trust, which will make it possible to always and under any
                circumstances keep up a high reputation of integrity, honesty, reliability
                and responsibility.


·
            To
                ensure the highest quality conduct of itsEmployees,
                Board of Directors andStaff.


·
            To
                maintain credibility, both institutional as well as individual, through
                the highest standards of ethical and professional conduct, for
                institutional operations as well as for generating
                business.


·
            To
                ensure that its commercial activities are being carried out pursuant
                to
                the legal rules applying to Bladex.


·
            To
                report, as far as possible, any possible conflicts of interest and
                independence.





**2.**  **Scope
      of Action**


The
      Bladex Code of Ethics shall apply to the Board of Directors as well as to all
      other S taff
      at
      the Head Office, Agencies, Representative Offices and Subsidiaries.





This
      Code
      of Ethics sets forth all standards of conduct for our Bank, the people
      representing it as well as the expectations of our Clients.





**3.**  **General
      Principles**


The
      Banking Business is based on an impeccable reputation of credibility and trust,
      as banks are the custodians of the business community’s financial resources. A
      bank’s success is measured by the degree of trust of its Customers and
      Investors. This trust depends on the honesty, integrity and high ethical
      standards of its staff, on keeping the confidentiality of information related
      to
      its Customers, on avoiding conflicts of interest and on complying with the
      laws
      and regulations governing the Bank’s activities.





Under
      no
      circumstances may personal conduct go against the Institutional
      interest.





It
      is a
      responsibility of all the people working at Bladex to ensure that the Bank’s
      values and principles are honored at all times, both inside the Institution
      as
      well as on the outside.





**4.**  **Individual
      Conduct, Personal and Professional Integrity**


The
      conduct of all Bladex Employees must be characterized at all times by
      professionalism, honesty, integrity and responsibility when fulfilling their
      assigned duties.





In
      the
      performance of their assigned jobs they shall have to adopt the same attitude
      as
      would be employed by honorable persons with solid character in their
      interpersonal relationships and the management of their own
      business.





Their
      conduct should reflect their personal and professional integrity, so that one
      can at all times expect a respectful, fair and objective treatment, avoiding
      abuse, bad manners, comments that go against the integrity and respect that
      the
      people with whom they are working and interacting in the performances of their
      assigned task are entitled to.





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Due
      to
      their position of trust, the personal finances of all the Bank’s employees
      should be handled prudently. Matters of personal finance must be managed in
      an
      upright manner and situations that might affect their image as well as that
      of
      the institution they represent should be avoided.





Employees
      are responsible for keeping up the ethical standards, including due controls
      over the accounting activities.





The
      following behavior shall be considered unacceptable and unbecoming while not
      in
      line with the Institution’s ethical values:





**4.1**  **External
      Matters**


·
            To
                carry out business transactions in representation of the Bank with
                institutions or companies in which they have some kind of personal
                or
                proprietary interest. If any such transactions are made for some
                reasons
                and under conditions of non-preferential treatment, then it is required
                to
                notify the Bank’s Head Compliance Officer in
                writing.


·
            To
                use their hierarchical position or information to which they may
                have had
                access for influencing decisions favoring their own interest or that
                of
                third parties.


·
            To
                engage in commercial transactions with Bladex Shares or with the
                shares in
                any other company and/or institution that is a Bladex Client, while
                in
                possession of important information that is not in the public domain.
                In
                other words, all employees are subject to restrictions regarding
                business
                transactions with inside
                information.


·
            To
                request, accept or offer any gifts or sinecures, either directly
                or
                indirectly with a representative or nominal value exceeding USD200.00
                (except for invitations regarding food and beverages), which could
                influence objective business decision
                making.


·
            To
                use the Bank’s funds for payments to any kind of organization, natural
                persons or government representatives, in order to obtain favors,
                business
                or to influence their decisions in favor of
                Bladex.





Note:
      Publications and speeches as well as interviews with the media and other public
      presentations related to the Bank, shall be previously approved by the Public
      Relations Department.





**4.2**  **Internal
      Matters**


·
            Any
                kind of discriminatory, harassing or intimidating behavior or attitude
                towards Employees.


·
            To
                use the equipment or facilities assigned for performing their duties
                for
                private purposes.


·
            To
                use time during working hours for private
                matters.


·
            To
                use or transfer technology, methods and processes developed for the
                use of
                the Institution, for private purposes or in benefit of any third
                parties.


·
            To
                violate established policies, rules and procedures to the detriment
                of the
                Institution.





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**5.**  **Managing
      Information**


Behavior
      shall always ensure the Bank’s best interests, maintaining confidentiality of
      its business and operations, as well as confidentiality of client’s information.
      This premise is especially important in the case of those Directors, Members
      of
      the Advisory Board or employees whose activities are directly or mainly related
      to the Bank’s line of business, or who have frequent or habitual access to
      confidential and privileged information of Bladex or its customers.





**5.1.
      Definitions** :





**a.
      Confidential Information:** All
      past,
      present of future information regarding the Bank and its business is considered
      confidential.





This
      includes, in a non-restrictive manner, information related to marketing and
      advertising plans, products, services, clients, markets, computer programs,
      equipment, configurations, processes, designs, finances. Confidential
      information can include commercial secrets and, in general, the information
      products, objects, trademarks and inventions protected by Intellectual Property
      laws.




**b.
      Privileged Information:** non-disclosed **** information
      concerning the activities of Bladex, a client or a member of its Economical
      Group, and whose knowledge could influence the price of stock, value titles
      or
      derived products of Bladex or of a Bladex client or its Economic Group.





In
      general, any information that may be used to decide to buy, sell or secure
      investments is privileged information, including the knowledge of, among
      others:





·  The
      company’s strategic Plan.


o  Expected
      financial results


o  Future
      expected income per share.


o  Any
      decision related to dividend payment.


·  Possible
      merges, acquisitions and/or strategic alliances.


·  Penal
      processes against the company.


·  Development
      of important products or services.


·  Decisions
      related to the company’s capital.





**c.** **“Banking
      Secrecy“:** The
      Banking Law of the Republic of Panama, that regulates the banking business
      in or
      from Panama, establishes that the banks shall only disclose information
      regarding their clients or the operation of said clients with their written
      consent, except when there exists a formal request from competent authority,
      in
      accordance with the law.





**d.
      Information considered as non Public:** Information
      must be considered as non public until it has been disclosed through public
      media and/or media previously established for this purpose. (Please refer
      section No.6 – Insider Trading)





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**5.2.
        Confidential and privileged information management**




**5.2.1
      Information received from clients**





a.
            Those
                employees authorized to request information from Bladex’s clients or
                future clients, will request the necessary information for their
                correct
                identification, as well as information about their financial situation,
                business plans and/or future objectives, when it is relevant for
                the
                services that are or will be offered.


b.
            Non-public
                information obtained from the clients or future clients, in accordance
                with the previously stated, will be private and
                confidential.





**Prohibitions:**


All
      confidential and privileged information to which access is granted must be
      exclusively used for authentic business purposes and for no purposes different
      from those for which it was requested. Besides, under no circumstance shall
      it
      be used for personal benefit or of third parties.





Directors,
      Members of the Advisory Board and employees could become exposed to civil suits
      and penal sanctions as consequence of the transgression of applicable
      regulations in the management of confidential and privileged information.





In
      this
      sense, Directors, Members of the Advisory Board and employees that have or
      may
      have frequent or customary access to relevant information concerning to Bladex
      client, will not be allowed to perform, promote or protect, directly or
      indirectly, any of the following behavior:




·
            Purchase
                or sell stock or any other investments while in possession of
                non-disclosed material and/or information concerning to Bladex client
                or
                its Economic Group.


·
            Disclose
                non-public material or information pertaining to Bladex, a Bladex
                client
                or its Economic Group, to a third party, including family members,
                friends
                or colleagues, so this information can be used by third parties to
                gain
                income in the Stock Market.


·
            Recommend
                or suggest to any person the purchase, selling or retaining of shares
                or
                other stock investments of a Bladex client or of its Economic Group.


·
            Grant
                access, to whom is not entitled to it, to non-public material or
                information pertaining to Bladex, a Bladex client or its Economic
                Group.





**5.2.2
      Bladex’s Information**




Financial
      information about the Bank and other information obtained inside the
      Institution, shall not be used to satisfy personal interests, or commented
      with
      third parties, unless it has been expressly transmitted by the Bank’s
      Administration in reports or through conferences intended for public knowledge.
      No direct or indirect advantage shall be obtained from that information. (Please
      refer section No.6 – Insider Trading)





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**5.2.3
      Information provided by Bladex to its employees, clients, investors, purveyors,
      outsourcing purveyors or competent authorities.**





a.
            All
                information shall be provided in accordance with the operational
                procedures established and following the legal requirements applicable
                to
                the Bank’s operations. In cases when providing information is required,
                approval from authorized persons shall be obtained and the information
                shall be provided in accordance with internally established policies,
                rules and procedures. .


b.
            Persons
                authorized by Bladex to provide information related to the Bank or
                its
                Group shall be extremely cautious with the purpose of avoiding any
                improper behavior in the use or transmission of the information.


c.
            The
                Bank Disclosure Committee shall previously review and evaluate all
                confidential and/or privileged information related to Bladex intended
                for
                disclosure to employees, clients, investors, purveyors, “outsourcing”
                purveyors or competent authorities.





**5.2.4
      Care and industriousness in information management**





Bladex
      must organize and permanently control the responsible usage of information,
      by
      adopting necessary measures and using adequate resources to efficiently perform
      its activity. In consequence:





a.
            Necessary
                administrative procedures shall be established for adequate control
                of
                information management and of risk levels derived from said information,
                ensuring that the access and safeguard of its computer media is sufficient
                for this purpose


b.
            It
                will be ensured that the information of each of the different areas
                of the
                Bank, derived from the respective specific activities performed in
                it,
                according to the current rules is not directly or indirectly available
                to
                the other areas of the Bank, therefore having autonomous and independent
                execution.





**6.1.
      Insider Trading**


Any
      confidential and/or privileged information obtained related to Bladex and its
      businesses shall be used solely for the legitimate purposes of Bladex’s business
      and not otherwise. Moreover, under no circumstances shall any Director, Members
      of the Advisory Board, Officer or employee buy or sell Bladex shares or
      securities, or carry out transactions related thereto, based on confidential
      or
      privileged information of material importance to Bladex and its businesses,
      regardless if such purchase is made for their own account, by proxy or a third
      party to whom such confidential or privileged information of material importance
      has been disclosed. This will subsist while there is an existing relationship
      with the Bank as well as when such relationship has ended.




Any
      Director, Members of the Advisory Board, Officer or employee, including the
      Bank
      itself, may be exposed to civil lawsuits or penalties as a result of any breach
      of regulations applicable to the handling of confidential and privileged
      information. To that effect, the Bank’s Directors, Officers and employees shall
      not carry out, promote or cover, on their own or another party’s account, either
      directly or indirectly, any type of transaction related to Bladex shares,
      without taking into account the internal policies set forth below.





7




**6.2.
      Window Period**


Window
      period is the time interval during which a publicly traded company permits
      its
      Directors, Members of the Advisory Board, Officers and employees to trade its
      stock.





Generally,
      unless there is any reason for the Bank to close this time interval during
      which
      a publicly traded company permits its Directors, Members of the Advisory Board,
      Officers and employees to trade its stock., the period set forth to carry out
      any type of trades of Bladex shares shall begin three (3) business days
      following the issue of the press release on the Bank’s financial results with a
      duration of forty-five (45) calendar days subsequent to the issue of the
      corresponding press release. The three (3) business day period as of the issue
      of the press release on the Bank’s financial results is referred to as a
“blackout period”.





Bladex
      shall retain the right to increase the length of the blackout period or restrict
      the window period at its discretion.





Directors,
      Members of the Advisory Board, Officers and employees shall give written
      notification using the form provided by the Bank of any type of trades of Bladex
      shares carried out, immediately upon their execution, to the following persons
      designated for this purpose:





·
            If
                a Bank Director, Members of the Advisory Board or Officer, including
                the
                CEO, notification should be made to the President of the Board of
                Directors of the Bank.


·
            If
                President of the Board of Directors of the Bank, notification should
                be
                made to the Chairman of the Audit and Compliance Committee of the
                Board of
                Directors..


·
            If
                a Bank employee, notification should be made to the CEO.





The
      above
      designated persons shall send copies of the completed notification forms
      received to the Bank’s Shareholders Relations Department (in case of Directors,
      Members of the Advisory Board and Officers), and to the Human Resources
      Department (in case of employees).




Notification
      forms are available through the Bank’s network or Shareholders Relations
      Department. A copy of the signed form, either an original or copy received
      by
      fax or in PDF format, shall be filed in the employee records of the
      corresponding Director, Members of the Advisory Board, Officer or employee
      kept
      in the Bank’s Shareholders Relations and Human Resources
      Departments.





The
      procedures established here are applicable to any type of purchase, sale or
      trade of Bladex shares (including shares obtained by exercising stock options),
      carried out on own account or through another party, either an individual or
      legal entity, including family members, friends or coworkers.





Notwithstanding
      the above, the Bank’s Directors, Members of the Advisory Board, Officers and
      employees shall abstain from carrying out trades of Bladex shares, even if
      within the window period set forth in this section, if they become aware of
      any
      confidential or privileged information of material importance related to Bladex
      and its businesses that has not been released to the market by Bladex.





8




**6.3
      Rule 10-b5-1 of the Securities and Exchange Commission**


Any
      Director, Members of the Advisory Board, Officer and employee has the option
      of
      adopting a pre-arranged stock trading plan in accordance with Rule 10b5-1 of
      the
      U.S. Securities and Exchange Commission, obtaining the right to negotiate Bladex
      shares in advance without violating Insider Trading policies.





**6.4**
            **Consequences
                of non-compliance with the policy on handling and control of confidential
                and privileged information**


Non-compliance
      pursuant to Sections 5 and 6 herein shall be subject to the imposition of the
      corresponding administrative sanctions, without prejudice to the outcome of
      the
      application of existing labor laws or any other standing order.





**7.**  **Customer
      Relations**


The
      Bank’s commitment with C ustomer S atisfaction
      shall be made clear by the respect and search of solutions for meeting their
      needs in parallel with the Bank’s profitability and business
      objectives.





All
      information provided by Bladex’s Customers shall be considered as confidential
      and for the Bank’s exclusive use. It is a responsibility of each and every one
      of the Bank’s employees to ensure that such information is not disclosed to
      those who are not legitimately entitled thereto. This applies to financial
      information, deposit and loan balances, information related to their management,
      future plans of our business clients, information obtained in the course of
      the
      Bank’s trust relationship as well as any other exclusive Bladex – Client
      relationship information.





All
      customers shall be treated courteously, providing them with all required
      information in a clear, concise and transparent manner. At no times should
      any
      preferential treatment be given for furthering their own interest or due to
      any
      personal affinity.





**8.**  **Shareholders
      Relations**


The
      relations with our shareholders are based on transparent, objective and timely
      communications that let them follow up on the Bank’s performance and progress at
      all times.





Any
      information that has not been publicly disclosed shall be kept as confidential
      in order to protect the Bank’s Shareholders’ Interest.





**9.**  **Relations
      with the Public Sector and Regulatory Entities**


Deference
      and courtesy by Bladex and its representatives towards members of the public
      sector and regulatory entities should be an institutional trait. Those
      relationships should never be used for personal advantage by people who work
      at
      Bladex.





High
      civic standards and respect for the law should be observed at all
      times.





Bladex,
      as a multinational institution, is subject to a series of laws and regulations
      for its operations in different countries. Any non-compliance with those laws
      and regulations could be the object of sanctions. It is a responsibility of
      each
      and every person to know and understand the legal aspects that apply to the
      performance of the tasks assigned to them, the activity of each of the
      Departments as well as of the Bank as a whole, in order to avoid any legal
      problems that could be caused for the Bank.





9




**10.**  **Interpersonal
      Relations** **in
      the Workplace**


As
      a
      world class Institution, Bladex pays a lot of attention to strengthening its
      social capital in its networking, both internally as well as externally, in
      order to achieve its business targets and institutional strengthening goals.
      In
      order for that to be possible, having a solid character should be distinctive
      trait of each of its Employees, so that the interpersonal relations, with
      regards to dealing with Customers and labor relations at the Bank, do reflect
      the highest levels and standards of trustworthiness.





Workplace
      relations shall at all times be distinguished by courtesy and respect. Each
      of
      the colleagues at the workplace should collaborate in creating a teamwork
      climate, full of trust and commitment, compatible with the Institution’s values.
      It is mandatory that the relations among coworkers be respectful of moral
      principles and that they do not attempt against family integrity





All
      persons holding a supervisory position shall role model their behavior on what
      they expect from their staff.





·
            The
                high professional level of interpersonal relations of Bladex Staff
                is
                mainly distinguished by:


·
            The
                quality of the results obtained by
                teamwork.


·
            The
                Satisfaction of the Bank’s
                Customers.


·
            The
                productive work climate that is focused on
                results.


·
            The
                respect for different individuals as well as for opinions that are
                contrary to their own.


·
            A
                fair, objective and equitable treatment at the
                workplace.


·
            Facilitating
                human and organizational growth and
                development.


·
            Rejecting
                obnoxious behavior, such as degrading words to describe a person,
                talk
                about third parties behind their backs, drug and alcohol
                addictions.


·
            Not
                spreading any rumors at the Bank.


·
            Complying
                with all institutionally established policies, rules and
                procedures.





**11.**  **Handling
      Conflicts of Interest**


The
      existence of any kind of personal interest in a transaction or work decision
      creates a conflict of interest situation that could get in the way of
      objectivity and good judgment in order for the best interest of the Bank to
      prevail. A conflict of interest would also be implied by using their position
      at
      Bladex in order to obtain personal benefits or advantages at the cost of the
      Bank.





Each
      and
      every Bladex Employee is entitled to their private life and the pursuit of
      their
      private interests outside the institution. Therefore, everyone is responsible
      for conducting their personal and financial matters as they may see fit,
      provided however that this is not a cause or appears to be a cause of conflict
      of interest with the Bank.





The
      following situations are considered as conflicts of interest:





·
            To
                partake in the approval or consideration of a credit, transaction
                or any
                other activity for his or her own benefit or that of a family member
                or of
                persons with whom business interests are
                shared.


·
            To
                request, accept or offer valuable gifts from the Bank’s suppliers or
                Customers, such as services, training, discounts or entertainment,
                with a
                representative or nominal value exceeding USD200.00 (except for
                invitations regarding food and beverages), which could be interpreted
                as a
                gesture for obtaining special privileges and not necessarily in the
                best
                interest or at the best terms for
                Bladex.






10




·
            To
                use their condition as a Bladex Employee for requesting preferential
                treatment or any kind of special concession in transactions of a
                personal
                nature.


·
            To
                invest in capital and/or debt issues of institutions that are Bladex
                Customers, with whom they have a direct business
                relationship.


·
            To
                hold positions such as Director, Members of the Advisory Board, Partner,
                Consultant or any other remunerated employment with institutions
                or
                corporations with which Bladex does business or that are considered
                to be
                competitors of the Bank. Should such a situation occur, then the
                Bank
                should be notified in writing and its approval
                obtained.


·
            Any
                other situation where there could be any doubt, although not included
                in
                this Code, should be consulted with the Bank’s Head Compliance Officer
                and/or Controller, in order to have it duly checked
                out.





**12.**  **Transactions
      with Related Parties**


Bladex
      should adhere to the regulatory guidelines establishing limitations on
      transactions between natural and juridical persons that are being considered
      as
“Related Parties”, as established by legislation in the different jurisdictions
      that apply to Bladex. Should there be any difference between those, than the
      strictest one shall be adopted.





Any
      transaction carried out with a Related Party must be assessed in the first
      instance by the Bank’s Legal Department. This review is in order to consider if
      such transaction does not contravene the laws and regulations enacted by the
      Government of the Republic of Panama, by the “Securities and Exchange Commission
      (SEC) of the United States or any other existing legal disposition.





Any
      transaction or transactions that are approved shall have to comply fully and
      at
      all times with all of the Bank’s established internal policies and
      procedures.





**13.**  **A
      High-Level Culture of Honesty and Ethics**


The
      Sarbanes-Oxley Act of 2002, proclaimed in the United States of America,
      establishes the obligation to ensure adequate internal controls at the
      Institution in order to:





·
            Be
                reasonably sure that transactions are duly recorded and they that
                are
                being carried out only according to the authorizations from the Board
                of
                Directors.


·
            Have
                designed effective internal controls to ensure that significant
                information about the Company and its consolidating subsidiaries
                is being
                disclosed.


·
            Public
                Companies must implement measures to avoid, dissuade and detect fraud.
                The
                implementation of such measures should be evidenced by a separate
                document
                drawn up by the Bank’s Management, in accordance with generally accepted
                international standards about that
                matter.





**14.**  **Administration
      of the Code** **of Ethics**


The
      Code
      of Ethics shall be reviewed periodically in order to keep it up to date as
      a
      function of the regulatory framework that applies to Bladex.





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**15.**  **Ethics
      Committee**


The
      Ethics Committee shall be responsible for ongoing evaluation and updating of
      this Code and review and implement the necessary mechanisms needed for
      disclosing and encouraging the highest standards of conduct at the
      Institution.





The
      Ethics Committee consists of:


Chief
      Executive Officer (CEO)


Controller


Senior
      Vice-President Administration and Human Resources


Head
      Compliance Officer


Internal
      Legal Counsel





**16.**  **Approval
      of and Modifications to the Code** **of Ethics**


The
      Code
      of Ethics will be approved by the Nomination and Compensation Committee of
      the
      Board of Directors, and it will also evaluate the modification proposals and/or
      updates that the Ethics Committee deems pertinent.





**17.**  **Compliance
      with the Code** **of Ethics**


The
      Directors of Bladex must strictly follow the Code of Ethics. The monitoring
      and
      compliance assurance of the stipulations of the Code of Ethics will be
      responsibility of the Audit and Compliance Committee of the Board of Directors,
      based on the reports that the Comptroller Area presents.





Each
      of
      the members of the Bladex team is responsible for the notification of any
      conflict of interests or non-compliance with the Code of Ethics, suspicious
      activities that could constitute transactions involving privileged information,
      frauds or fraud attempts, accounting registers that do not comply with generally
      accepted accounting principles, as well as any mysterious disappearance of
      funds
      or titles. The employee may report these to the persons that the Bank
      establishes for this purpose, following the procedures or systems established
      for it.





In
      the
      case of Bank employees, the sanctions for Code of Ethics violations will be
      joint responsibility of the supervisors and the CEO, and in the case of the
      Directors, the sanctions will be responsibility of the Nomination and
      Compensation Committee of the Board of Directors. The Ethics Committee will
      be
      informed of these sanctions.





**18.**  **Other
      Considerations**


The
      Code
      of Ethics is part of the Bank’s regulatory framework, together with the
      Discipline and Internal Rules and Regulations, the Compliance Manual, the
      Procedures, Standards and Policies Manuals as well as other Operating
      Instructions.





Should
      there be any doubt about the interpretation of the contents of this Code or
      the
      respective application thereof, or particularly about conflicts of interest,
      then the Bank’s Head Compliance Officer or Controller should be
      consulted.





12


**BANCO
      LATINOAMERICANO DE EXPORTACIONES, S.A. (“Bladex”)**





**ADDENDA
      (THE “ADDENDA”) TO THE CODE OF ETHICS OF OCTOBER 2002 (THE “CODE”) FOR THE MAIN
      EXECUTIVES AND THE TOP FINANCIAL EXECUTIVES**





The
      Chief
      Executive Officer, Executive Vice President - Chief Operating Officer, the
      Senior Vice President & CFO and the Vice President - Principal Accountant,
      as Bladex top executives (the “Top Executives”), herewith and hereby accept the
      contents of the Bladex Code of Ethics and agree to be bound by the additional
      disposition contained herein.





**I.
      This Addenda applies to all Top Executives at Bladex, with the purpose of
      encouraging:**





·
            Honest
                and ethical conduct, including ethical management of actual or apparent
                conflicts of interest between their personal and professional
                relationships;


·
            A
                complete, fair, precise, timely and understandable disclosure in
                the
                reports and documents that Bladex issues or files with the Securities
                and
                Exchange Commission (“SEC”) as well as in other public communications made
                by Bladex;


·
            Compliance
                with applicable laws and governmental rules and
                regulations;


·
            Timely
                internal reports about violations of the Code to an appropriate person
                or
                to the persons identified in the Code;
                and


·
            Responsibility
                for adhering to the Code.





All
      Top
      Executives shall adhere to high ethical business standards and should be
      sensitive about situations that could result in an actual or apparent conflict
      of interest. Bladex expects that its T op
      Executives comply at all times with the principles of this Code. Any violation
      of this Code shall be cause for disciplinary actions, including dismissal and
      possible legal action. Any consultations about the application of this Code
      should be referred to the Bladex Board of Directors’ Audit and Compliance
      Committee.





**II.
      Top Executives should ethically manage actual or apparent conflicts of
      interests.**





***Summary*** **:** A
“ C onflict
      of Interest” occurs when a Top Executive’s private interest interferes with the
      interest of, or his or her service at, Bladex. For example, a T op
      Executive’s conflict of interest could arise if a T op
      Executive or a member of his or her family would receive improper personal
      benefits as a result of his or her position at Bladex.





The
      existence of any kind of personal interest in a transaction or work decision
      creates a conflict of interest situation that could get in the way of
      objectivity and good judgment in order for the best interest of the Bank to
      prevail. A conflict of interest would also be implied by using their position
      at
      Bladex in order to obtain personal benefits or advantages at the cost of the
      Bank.





Each
      and
      every Bladex Employee is entitled to their private life and the pursuit of
      their
      private interests outside the institution. Therefore, everyone is responsible
      for conducting their personal and financial matters as they may see fit,
      provided however that this is not a cause or appears to be a cause of conflict
      of interest with the Bank.





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The
      following situations are considered as conflicts of interest:


·
            To
                partake in the approval or consideration of a credit, transaction
                or any
                other activity for his or her own benefit or that of a family member
                or of
                persons with whom business interests are
                shared.


·
            To
                request or accept valuable gifts from the Bank’s suppliers or Customers,
                such as services, training, discounts or entertainment, which could
                be
                interpreted as a gesture for obtaining special privileges and not
                necessarily in the best interest or at the best terms for
                Bladex.


·
            To
                use their condition as a Bladex Employee for requesting preferential
                treatment or any kind of special concession in transactions of a
                personal
                nature.


·
            To
                invest in capital and/or debt issues of institutions that are Bladex
                Customers, with whom they have a direct business
                relationship.


·
            To
                hold positions such as Director, Members of the Advisory Board, Partner,
                Consultant or any other remunerated employment with institutions
                or
                corporations with which Bladex does business or that are considered
                to be
                competitors of the Bank. Should such a situation occur, then the
                Bank
                should be notified in writing and its approval
                obtained.





In
      situations involving a Top Executive, where the appearance or the potential
      of a
      conflict of interest is involved, but where the T op
      Executive does not believe that a significant conflict of interest exists,
      the T op
      Executive should obtain approval from the Audit and Compliance Committee before
      getting involved in that situation. No such approval shall be considered as
      a
      waiver of this Code.





**III.
      Disclosure and Compliance**


·
            All
                Top Executives should familiarize themselves with the disclosure
                and
                compliance requirements that are generally applicable to
                Bladex;


·
            All
                Top Executives should not distort, or cause others to distort, facts
                about
                Bladex, whether within or without Bladex, including Bladex Directors
                and
                Auditors, or to government regulators and autonomous organizations;


·
            AllTop
                Executives must, as far as appropriate in their area of responsibility,
                consult with other Bladex Executives andEmployees
                in order to promote full, fair, precise, timely and understandable
                disclosure in reports issued by Bladex or filed with the SEC, as
                well as
                in other public communications made by Bladex;
                and


·
            It
                is a responsibility of all Top Executives to encourage compliance
                with the
                standards and restrictions imposed by applicable laws, rules and
                regulations.





**IV.
      Reports and Responsibilities**


All
      top
      Executives shall:





·
            Once
                this code has been adopted (or if applicable later on, upon becoming
                aTop
                Executive), file a written statement with the Board of Directors
                that they
                have received, read and understood this
                Code;






14




·
            Not
                take any retributive actions against any other Bladex Top Executive
                or
                Employee or their family members for reports about potential violations
                that were made in good faith.


·
            Promptly
                notify the Audit and Compliance Committee if they are aware of any
                violation to this Code. To omit any such notification shall be considered
                as a violation of this Code.





The
      Audit
      and Compliance Committee is responsible for applying this Code in specific
      situations where there could be some doubt, and they have the authority to
      construe this Code for any particular situation. Any exception for a Top
      Executive should be considered by the Audit and Compliance
      Committee.


Bladex
      shall follow the following procedures when investigating compliance with this
      Code:





·
            The
                Audit and Compliance Committee shall take all appropriate actions
                necessary for investigating any potential violation that may have
                been
                reported to them;


·
            If,
                after investigating, the Audit and Compliance Committee believes
                that no
                violation has occurred, then it is not required for the Audit and
                ComplianceCommittee
                to take any further action;


·
            If
                the Audit and Compliance Committee should determine that there has
                been a
                violation, then they shall consider the appropriate measures that
                could
                include a review of, or revision to, the applicable policies and
                procedures; or the recommendation for dismissing the Top
                Executive;


·
            The
                Audit and Compliance Committee shall be responsible for granting
                waivers
                to thisCode,
                as may be appropriate; and


·
            Any
                change or exception to thisCode
                shall be disclosed to the necessary extent, as established by SEC
                Regulations.





**V.
      Changes or Exceptions to the Code**


Any
      and
      all exceptions stipulated in this Code shall be reported to and filed with
      the
      SEC and shall be reported to Bladex Shareholders within the timeframe required
      by SEC Regulations and any applicable laws from any banking regulator or
      regulators of securities and stock markets where Bladex is listed.





**VI.
      Other Policies and Procedures**


This
      Code
      shall be the only Code of Ethics adopted by Bladex, with regards to the
“Sarbanes-Oxley Act” of 2002 and the rules and regulations applying to companies
      listed therein.





**VII.
      Amendments**


Any
      amendment to this Code must be approved by the Nominating and Compensation
      Committee and ratified by a majority vote of the Board of Directors’ Audit and
      Compliance Committee.





**VIII.
      Confidentiality**


All
      reports and records drawn up or kept pursuant to this Code shall be considered
      as confidential and shall be kept and protected as such. Except where required
      by Law or by this Code, such matters shall not be disclosed to anybody outside
      the Audit and Compliance Committee and the Board of Directors of
      Bladex.





15




**IX.
      Internal Use**


This
      Code
      is exclusively for the internal use of Bladex and does not represent any
      admission, by or in behalf of, Bladex, of any fact, circumstance or legal
      conclusion.





I
      have
      read and understood the terms of the Code. I recognize the responsibilities
      and
      obligations incurred by me as a result of being subject to this Code. I herewith
      express my agreement to comply with this Code.





/s/
                Jaime Rivera
            
            /s/
                Miguel MorenoChief
                Executive Officer
            
            Executive
                Vice President - Chief Operating Officer/S/
                Jaime Celorio
            
            /s/
                Enrique GainesSenior
                Vice President &CFO
            
            Vice
                President-Principal Accountant





16