Exhibit 11.1













CODE OF ETHICS





















Updated: July 2015

Approved by the Nomination and Compensation
Committee in its meeting held on July 13, 2015, as stated in the corresponding minutes.











INTRODUCTION



The set of ethical principles adopted
by Banco Latinoamericano de Comercio Exterior, S.A. (“Bladex”)shall be a guideline for its Board of Directors
and team of Employees regarding the independent performance of business transactions as well as for their personal and interpersonal
conduct, both within and without the Bank.



These ethical principles shall also
be for ensuring and enhancing the image of an Organization that can be relied upon because of its sound principles and values.



Bladex, as a supranational bank with
a shareholding structure representing the public and private sectors, has to deal with a series of different interests that require
guidelines for carrying out its business. To this extent, the values of the Bank: Commitment, Humility, Excellence, Respect and
Integrity constitute the foundations of its organizational culture and are the framework for the individual and collective behavior
of all employees.



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 Executive Team, for promoting the highest ethical standards, as well as for promoting and strengthening an organizational
culture focused on values and showing and emphasizing to all Employees 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, Vendors and Employees. At the same time, each Supervisor shall ensure that his/her subordinates
participate exclusively in such assignments and tasks for which they possess the required knowledge, abilities and expertise.



1







| | 1. | Objectives
| | -- | ----------



The Bladex Code of Ethics pursues
the following objectives:



| | Ø | To act as a guideline for establishing
relationships based on trust, both within as well as without the Bank, which will make it possible to always and under any circumstances
keep up a high reputation of Commitment, Humility, Excellence, Respect and Integrity.
| | - | ---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
| |   |                                                                                                                                                                                                                                                                      

| | Ø | To ensure the highest quality conduct
of its work team, Board of Directors, and Staff.
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| |   |                                                                                       

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

| | Ø | To ensure that its commercial activities
are being performed in accordance with the legal regulations applying to Bladex
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| |   |                                                                                                                         

| | Ø | To report, as far as possible, any potential
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 Staff at the Head Office, Agencies, Representation Offices and Subsidiaries.



This Code 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 custodians of the business community’s financial resources.
A bank’s success is measured by the degree of trust demonstrated by its Clients and Investors.



This trust is contingent on
the manner in which the members of the organization achieve excellence through commitment, humility, respect and integrity in the
performance of their duties, thus extolling the high ethical standards represented by Bladex, the protection of confidentiality
of information related to its Clients, the avoidance of conflicts of interest and compliance with the laws and regulations governing
the Bank’s activities.



Under no circumstances may personal
conduct go against organization values and interests.



All Bladex staff members are
responsible for ensuring that the Bank’s values and principles are honored at all times, both within as well as out of the
organization.





2







| | 4. | Conduct and Behavior Based on Organizational Values
| | -- | ---------------------------------------------------



The conduct of all Bladex Employees
must be characterized, at all times, by modeling the values of the organization: commitment, honesty, excellence, respect and integrity
when fulfilling their assigned duties and in their interpersonal relationships.



In the performance of their
assigned duties, they shall adopt the same attitude that honorable persons with a sound character would manifest in their interpersonal
relationships and the management of their own business.



The conduct of the members of
the Board of Directors and that of all Bladex Employees shall at all times reflect the values of the Bank, always driven by the
goal of achieving excellence. Likewise, behaviors must be modeled as associated with each of the following values.



Commitment:

| | · | Put the success of the organization ahead of our own interest
| | - | -------------------------------------------------------------



| | · | Work together constructively
| | - | ----------------------------



| | · | Be aligned with the Bank’s strategy and personally committed to the objective of the organization
| | - | -------------------------------------------------------------------------------------------------



Humility:

| | · | Admit our mistakes and learn from them
| | - | --------------------------------------



| | · | Acknowledge the contributions made by others
| | - | --------------------------------------------



| | · | Accept feedback
| | - | ---------------



Excellence:

| | · | Give our very best
| | - | ------------------



| | · | Exceed our own and our clients’ expectations
| | - | --------------------------------------------



| | · | Keep up to date with the necessary skills and knowledge to perform our duties
| | - | -----------------------------------------------------------------------------



Respect:

| | · | Treat other people nicely
| | - | -------------------------



| | · | Foster harmony in interpersonal relationships
| | - | ---------------------------------------------



Integrity:

| | · | Be transparent, honest, professional and reliable
| | - | -------------------------------------------------



| | · | Promote and enforce standards for appropriate behavior
| | - | ------------------------------------------------------



| | · | Have zero tolerance for fraud or corruption
| | - | -------------------------------------------



Due to their position of trust,
the personal finances of all of the Bank’s Employees should be managed with caution. Matters of personal finance must be
conducted in an upright manner, avoiding situations that might affect their image and that of the organization they represent.





3







Employees are responsible for
maintaining ethical standards, including due controls over accounting activities.



Any behavior to the detriment
of the value of the organization shall be considered unacceptable and is not in line with the ethical values of the organization.



| | 4.1. | External Matters
| | ---- | ----------------



| | - | To carryout business transactions in representation of the Bank, with institutions or companies
in which they have some type of personal and/or proprietary interest. If, for any reason and under no preferential treatment conditions,
the aforementioned transactions are performed, the Bank’s Senior Vice-President - Compliance shall be informed in writing.
| | - | -------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------



| | - | To use their hierarchical position or the information to which they have access to influence decisions
favoring personal or third parties’ interests.
| | - | -----------------------------------------------------------------------------------------------------------------------------------------------------



| | - | The performance of business transactions with Bladex’s Securities or with the securities
of any other company and/or institution that is a Bladex Client, while in possession of important insider information that is not
in the public domain. In other words, all Employees and Directors of the Bank are subject to restrictions regarding commercial
transactions with inside information. (Refer to Section 6: Insider Trading).
| | - | --------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------



| | - | To directly or indirectly request, accept or offer gifts or sinecures, with a representative or
nominal value exceeding USD 200.00 (except for Invitations regarding food and beverages), which could influence objective decision
making.
| | - | ------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------



| | - | To use the Bank’s funds for payments to any type of organization, individuals or government
representatives, in order to obtain favors, business or to influence their decisions in favor of Bladex.
| | - | ----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------



Note:   Publications, speeches,
interviews with the media and other public presentations, in matters related to the Bank, shall be previously approved by the Institutional
Relations and Marketing Department.



| | 4.2. | Internal Matters
| | ---- | ----------------



| | - | Any type of discriminatory, harassing or intimating attitude or behavior towards Employees.
| | - | -------------------------------------------------------------------------------------------



| | - | The usage of equipment or facilities assigned for the performance of their duties for personal
purposes.
| | - | --------------------------------------------------------------------------------------------------------



| | - | The usage of time during working hours for personal matters.
| | - | ------------------------------------------------------------

| | - | The usage or transfer of technology, methods and processes developed for the use of the Institution
for personal purposes or in benefit of third parties.
| | - | ---------------------------------------------------------------------------------------------------------------------------------------------------------



| | - | Infringement of established policies, rules and procedures in detriment of the Organization.
| | - | --------------------------------------------------------------------------------------------





4







| | 4.3. | Preventing the Consumption of Illegal Substances
| | ---- | ------------------------------------------------



The Bank recognizes that the consumption
of illegal substances is a real problem nowadays and that such behavior could harm the health and quality of life of people and
their families, negatively impacting the society we live in. Therefore, the Bank’s Employees are prohibited from consuming
illegal substances.



Upon hiring each Employee, the Bank shall
undertake such tests as may be permitted by current laws in force for detecting the consumption of illegal substances.



| | 5. | Managing Information
| | -- | --------------------



We should always act in the best interests
of the Bank, maintaining confidentiality of its business and operations, as well as the confidentiality of its Clients’ 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 regular access to confidential and
insider information of Bladex or its Clients.



| | 5.1. | Definitions:
| | ---- | ------------



| | a. | Confidential Information:All past, present or future information about 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, technology applications,
equipment, configurations, processes, designs and finance. Confidential information may include commercial secrets and, in general,
information, products, objects, trademarks and inventions protected by Intellectual Property Laws.



| | b. | Insider Information:Information concerning the activities of Bladex or of a Client of Bladex
or of its Economic Group, that has not been disclosed to the public or to third parties and the knowledge of which could influence
the price of stock, securities or derived products of Bladex or of a Bladex Client or of its Economic Group, including information
about, among others:
| | -- | ---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------



 ̈ A company’s
strategic plan

 ̈ Expected financial
results

 ̈ Future expected
earnings per share

 ̈ Any decision
related to dividend payments

 ̈ Possible mergers,
acquisitions and/or strategic alliances.

 ̈ Criminal proceedings
against the company or its Main Executives

 ̈ Development of
important products or services

 ̈ Decisions related
to the company’s capital





5







| | c. | “Banking Secrecy”:The Banking Law of the Republic of Panama, which regulates
the banking business in or from Panama, establishes that banks shall only disclose information regarding their clients or the operations
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 information
until it has been disclosed, by the same person to whom such information belongs, through public media and/or media previously
established thereto. In addition, information will maintain the condition of non-public until it has been disseminated. (Please
refer to section No 6 – Insider Trading)
| | -- | -----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------



| | 5.2. | Managing Confidential and Insider Information
| | ---- | ---------------------------------------------



| | 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 by the Bank and/or its
subsidiaries to such Clients or future Clients.
| | -- | ------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------



| | b. | Non-public information obtained from Clients or future Clients, in accordance with the previously
stated, shall be considered as insider and confidential information.
| | -- | ----------------------------------------------------------------------------------------------------------------------------------------------------------------------



Prohibitions:



Based on the above, it is prohibited
to use any confidential and insider information for illegitimate business purposes, for purposes different from those for which
it was requested or for personal benefit or that of third parties or family members that are closely related to the Employee.



Directors, Members of the Advisory
Board, Employees and the even Bank itself could become exposed to civil suits and criminal sanctions as a consequence of the violation
of applicable regulations in the management of confidential and inside information.



In this sense, Directors, Members
of the Advisory Board and Employees that have or may have frequent, regular or occasional access to relevant information concerning
a Bladex Client, will not be allowed to perform, promote or protect, on their own behalf or that of a third party, directly or
indirectly, any of the following behaviors:





6







| | Þ | Buy or sell stock or any other investments
while in possession of, or, after becoming aware of or receiving non-disclosed material and/or insider information concerning
a Bladex Client or its Economic Group that has not been made public yet.
| | - | -------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------



| | Þ | Disclose non-public material or insider
information pertaining to a Bladex Client or its Economic Group, to a third party, including family members, friends or colleagues,
so that this information can be used by third parties to make a profit in the Securities Market.
| | - | ----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------



| | Þ | Recommend or suggest to any person the
buying, selling or retaining of shares or other securities investments in a Bladex Client or of its Economic Group.
| | - | ----------------------------------------------------------------------------------------------------------------------------------------------------------



| | Þ | Grant access, to whom is not entitled
to it, to non-public material or insider information pertaining to a Bladex Client or its Economic Group.
| | - | -----------------------------------------------------------------------------------------------------------------------------------------------



| | 5.2.2. | Information about Bladex
| | ------ | ------------------------



Financial information about the
Bank and other information obtained inside the Institution shall neither be used to satisfy personal interests, nor commented with
third parties, unless it has been expressly transmitted by the Bank’s Management in reports or through conferences intended
for the public knowledge. No direct or indirect advantage shall be obtained from such information. (Please refer to section No
- 6 Insider Trading):



| | 5.2.3. | Information provided by Bladex to its Employees, Directors, Clients, Investors, Suppliers, Vendors,
Outsourcing Providers 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’s Disclosure Committee shall previously review and evaluate all confidential and/or
insider information related to Bladex intended for disclosure to Employees, Directors, Clients, Investors, Suppliers, Vendors,
Outsourcing Providers or Competent Authorities.
| | -- | ---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------





7









| | 5.2.4. | Care and Diligence in Information Management
| | ------ | --------------------------------------------



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



| | a. | The necessary administrative procedures shall be established for adequate control of information
management and of the risk levels derived from said information, ensuring that the access and safeguard systems of its IT media
are 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 there, according to current rules and regulations is not, directly or indirectly,
available to the other areas of the Bank, so that each function shall operate autonomously and independently.
| | -- | ---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------



| | 6. | Insider Trading (Regarding Bladex)
| | -- | ----------------------------------



All confidential and/or insider information
obtained related to Bladex and its business shall be used solely for the legitimate purposes of Bladex’s business and not
otherwise. Moreover, under no circumstances shall any Director, Member of the Advisory Board, Officer or Employee buy or sell Bladex
shares or securities, or carry out transactions related thereto, based on confidential or insider information of material importance
regarding Bladex and its business, regardless if such purchase is made for their own account, by
proxy or a third party to whom such confidential or insider 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, Member of the Advisory Board,
Officer or Employee, and even the Bank itself, may be exposed to civil lawsuits or criminal charges as a result of any breach of
regulations applicable to the handling of confidential and inside information. To that effect, the Bank’s Directors, Members
of the Advisory Board, 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.



| | 6.1. | Window Period:
| | ---- | --------------



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



Generally, unless there is any
reason for the Bank to close this time interval during which its Directors, Members of the Advisory Board, Officers and Employees
are permitted to trade its stock, the period set forth to carry out any type of trades in 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 period that begins after the forty-five (45) calendar days
of the Window Period and ends after the three (3) business days following the next press release of the Bank’s financial
results is referred to as a Blackout Period.





8







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 submit written notification using the form provided by the Bank thereto of any type of trades
of Bladex shares carried out, immediately upon their execution, to the following persons designated for this purpose:



| | · | For Bank Directors, Members of the Advisory
Board or Officers, including the CEO, notification should be made to the Chairman of the Board of Directors of the Bank with a
copy to the Shareholder Relations Department.
| | - | ------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------



| | · | For the Chairman of the Board of Directors
of the Bank, notification should be made to the Chairman of the Audit and Compliance Committee of the Bank with a copy to the Shareholder
Relations Department.
| | - | ----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------



| | · | For Bank Employees, notification should
be made to the CEO with a copy to the Human Resources Department.
| | - | ---------------------------------------------------------------------------------------------------------



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, Member of the Advisory Board, Officer
or Employee kept in the Bank’s Shareholders Relations and Human Resources Departments.



The procedures established herein
are applicable to any type of purchase, sale or trade of Bladex shares (including shares obtained by exercising stock options),
carried out on their 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 refrain from carrying out trades in Bladex
shares, even if within the “Window Period” set forth in this section, if they become aware of any confidential or insider
information of material importance related to Bladex and its business that has not been disclosed to the market by Bladex.





9







Any of the above mentioned individuals
to whom this policy is applicable who does not comply with the dispositions contained herein and performs a transaction of selling/buying
shares during the restricted period (outside the Window Period), shall reverse said transaction within two (2) weeks. Any profits
obtained from this reversion shall be handed to the Bank and any loss shall be assumed by the individual.



The Audit and Compliance Committee
of the Board of Directors shall determine the severity of the infringement and shall apply such disciplinary measures as it may
deem to be appropriate.



| | 6.2. | Securities and Exchange Commission (SEC) Rule 10b5-1
| | ---- | ----------------------------------------------------



Any Director, Member of the
Advisory Board, Officer and Employee of the Bank has the option of adopting a pre-arranged stock trading plan, instruction or agreement
in accordance with Rule 10b5-1 of the U.S. Securities and Exchange Commission Act of 1934, that allows the buying and/or selling
of the Bank’s shares during the Black-Out periods.



Such pre-arranged plan, instruction
or agreement for buying and selling shares being adopted with the respective broker may only be implemented during a Window Period
and should specify the quantity of shares to be sold or bought as well as the price and the date of selling or buying them. As
an alternative to the above, some written formula or algorithm or computer program may be included as shall operate for determining
the quantity, price and data for selling or buying the stock.



Such pre-arranged plan, instruction
or agreement shall prohibit that the interested party may modify or alter the quantity, price and date for selling or buying the
shares later on, unless such modification is made during a Window Period, when the interested party does not have any knowledge
of any confidential or insider information.



Any pre-arranged plan, instruction
or agreement for buying and selling shares that one wishes to use should first be approved in writing, before becoming valid, by
the following authorities:



| | · | If the pre-arranged plan, agreement or
instruction for buying and selling shares is for a Director, Member of the Advisory Board or Officer of the Bank, including the
CEO, then it must be approved by the Bank’s Chairman of the Board.
| | - | -----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------



| | · | If the pre-arranged plan, agreement or
instruction for buying and selling shares is for the Bank’s Chairman of the Board, then it must be approved by the Chairman
of the Bank’s Audit and Compliance Committee.
| | - | ----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------



| | · | If the pre-arranged plan, agreement or
instruction for buying and selling shares is for an Employee of the Bank, then it must be approved by the Bank’s CEO.
| | - | ------------------------------------------------------------------------------------------------------------------------------------------------------------





10







Apart from that, for Directors,
Members of the Advisory Board, Officers and the Chairman of the Board of Directors of the Bank, a copy of the pre-arranged plan,
agreement or instruction for selling and buying shares should be sent to the Shareholder Relations Department and, for the Bank’s
Employees, this copy should be sent to the Human Resources Department.



Transitory Paragraph: Such pre-arranged
plans, agreements and instructions as may already exist and were set up prior to the validity of this Code of Ethics, should be
approved pursuant to the previous paragraph.



Revoking and Modifying Pre-Arranged
Plans, Agreements or Instructions for Buying and Selling Shares:



Any Director, Member of the
Advisory Board, Officer and Employee of the Bank may revoke their pre-arranged plan, agreement or instruction during a Window Period
by notifying their broker in writing.



Under certain circumstances,
a Pre-Arranged Plan, Agreement or Instruction for buying or selling shares should be revoked. This includes such circumstances
as the announcement of a merger or any event that would cause such transaction to be in violation of the law or to have an adverse
effect on the Bank. In such circumstances, the Shareholder Relations Department is authorized to notify the Broker of the owner
of the Pre-Arranged Plan, Agreement or Instruction thereof.



| | 6.3. | Insider Trading (regarding Customers)
| | ---- | -------------------------------------



All confidential and insider
information about the Clients of Bladex and/or its subsidiaries that is being held, received or known, shall be used exclusively
for legitimate purposes of the Bank’s business. Under no circumstances may any Director, Member of the Advisory Board, Officer
or Employee buy, sell or engage in any transactions with any shares or securities of Clients or their economic groups, based on
confidential and insider information with a material significance, whether such transactions are made on their own behalf, by proxy
o closely related family member, for family members (to the second degree of consanguinity and first degree of affinity), or for
any other person close to them, to whom such materially significant confidential or insider information was disclosed.



| | 6.4. | Consequences of Non-Compliance with the Policy on Handling and Control of Confidential and Insider
Information
| | ---- | --------------------------------------------------------------------------------------------------------------



Non-compliance
pursuant to Sections 5 and 6 hereof 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 applicable, internal or external rules or regulations in
force.



11







| | 6.5. | Transactions after having Terminated the Relationship with the Bank
| | ---- | -------------------------------------------------------------------



The policies set forth herein
shall continue to be applicable to transactions with the Bank’s shares, even after having terminated the relationship as
Director, Member of the Advisory Board, Officer and Employee of the Bank, In the event that any such person would have confidential
or insider information of material importance when the relationship with the Bank ends, such persons may not trade in the Bank’s
shares until such information has become public or ceases to be of material importance. However, the exercise of stock options
granted by the Bank is excepted form this prohibition.



It shall be the responsibility
of each ex-employee to comply with the insider trading rules established by law.



| | 7. | Relations with Customers and Service Providers
| | -- | ----------------------------------------------



The Bank’s commitment with Customer
Satisfaction shall be made clear by the respect and search of solutions meeting their needs in parallel with the Bank’s profitability
and business objectives.



All customers and service providers 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 personal interests or due to any personal affinity.



In the case of service providers such as
External Auditors, the Bank shall comply with the foregoing, as well as with the provisions of the SEC’s Independence Standards
Boards (“ISB”) Standard No.1 and the Sarbanes-Oxley Act, with regards to the independence rules forbidding the hiring
of staff from the external auditing firm who have been a part of the team auditing the financial statements of the Bank and its
subsidiaries for the past two years.



| | 8. | Shareholders Relations
| | -- | ----------------------



The relations with our shareholders are
based on transparent, objective and timely communications that will let them monitor 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 interests of the Bank’s Shareholders.



| | 9. | Relationships 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 organizational trait. Those relationships
should never be used for personal advantage by people who work at Bladex.



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





12







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 o 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.



| | 10. | Interpersonal Relationships at the Workplace
| | --- | --------------------------------------------



As a world-class organization, 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 organization strengthening goals. In order for that to be possible, being of sound character should be
a 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 humility 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.



The Bank respects the right to privacy
of its employees, therefore, matters of a personal nature concerning current or past employees of the Bank, shall be treated in
strict confidentiality. Spreading rumors referring to third parties is considered a lack of character and integrity.



All persons holding a supervisory position
shall role model their values and behavior on what they expect from their team members.



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



| | · | The quality of the results obtained through
teamwork;
| | - | -----------------------------------------------------



| | · | The Satisfaction of the Bank’s Clients;
| | - | ---------------------------------------



| | · | The productive work climate that is focused
on results;
| | - | -------------------------------------------------------



| | · | The respect for individual differences
as well as for opinions that are contrary to their own;
| | - | ----------------------------------------------------------------------------------------------



| | · | Humility in accepting and receiving feedback
and ideas from others;
| | - | -------------------------------------------------------------------



| | · | A fair, objective and equitable treatment
at the workplace;
| | - | -----------------------------------------------------------



| | · | Facilitating human and organizational
growth and development;
| | - | -------------------------------------------------------------





13







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



| | · | Not spreading any rumors at the Bank;
| | - | -------------------------------------



| | · | Complying with all established policies,
rules and procedures in the Organization.
| | - | ----------------------------------------------------------------------------------



| | 11. | Handling Conflicts of Interest
| | --- | ------------------------------



Directors and Employees must avoid situations
that could present a conflict of interest in order to mitigate and minimize any risks and adverse impacts on the Bank. Should a
conflict of interest arise, the Director of Employee should follow the guidelines set out in this section to handle the conflict
of interest.



A conflict of interest is a situation in
which an interest (arising from an ownership or a management relationship) interferes or could interfere with a person's ability
to act in the interest of another party when that person has a (legal, conventional, fiduciary or ethical) obligation to act in
the interest of the other party.



In this respect, a conflict of interest
arises when a Bank Employee or Director is influenced by a type of personal interest (or even institutional) that hinders them
from working objectively, exercising good judgment and in the best interests of the Bank.



A conflict of interest could also arise
when an employee or Director uses their position at Bladex for personal gain or to benefit a "Related Party.” For the
purposes of this section, a Related Party with respect to a Bank Employee or Director is understood to be: (1) their spouse, (2)
family members within the fourth degree of consanguinity, (3) any company in which they are owner or beneficiary, directly or indirectly,
of 5% or more of the stock and (4) any company in which they hold a Directorship or management position, or to which they provide
consulting or hold any other paid position.



Each and every Bladex Employee is entitled
to their private life and the pursuit of their private interests outside the organization. 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:



| | · | Involvement in the approval or consideration
of a credit, transaction or any other activity for his or her own benefit, of that of a shareholder of Bladex represented by the
Director or that of any Related Party.
| | - | --------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
| |   |                                                                                                                                                                                                                     

| | · | A request for, acceptance of or offer
of valuable gifts to the Banks 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.
| | - | -------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------





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| |  | 
| |  | 

| | · | Use of position as a Bladex Employee for
requesting preferential treatment or any kind of special concession in transactions of a personal nature.
| | - | --------------------------------------------------------------------------------------------------------------------------------------------------
| |   |                                                                                                                                                   

| | · | Investment in capital and/or debt issues
of institutions that are Bladex Customers, with whom there is a direct business relationship that is managed by the Employee and
which would amount to more than 2% of the total, in each case.
| | - | ----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
| |   |                                                                                                                                                                                                                                         

| | · | Position such as Director, 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.
| | - | ----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
| |   |                                                                                                                                                                                                                                                                                                                 

| | · | An attempt to do business with the Bank
directly or through any Related Party.
| | - | ------------------------------------------------------------------------------



Any situation arising that could involve
a conflict of interest should be reported immediately by the Employee or Director. Employees should report potential conflicts
of interest to the heads of Compliance and/or Internal Audit and Directors to the Chairman of the Audit and Compliance Committee.
Moreover, the Employee or Director involved should refrain from deliberating or voting on any related resolution or decision made
by the Bank.



Any situation involving an Employee of
the Bank where there is doubt as to whether a conflict exists because it is not covered by this Code, the Employee should consult
the heads of Compliance and/or Audit of the Bank for verification.



Any other situation involving a Director
of the Bank where there could be any doubt, although not included in this Code, should be consulted with the Heads of the Compliance
and/or Audit Department at the Bank, 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, then 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 Risk Department and the Compliance 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 applicable
to the Bank.





15







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 organization in order to:



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



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



| | ü | Publicly traded 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.
| | - | -----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------



The Bank requires all data on operational
risk events and incidents to be stores. All Employees of Bladex are required to ensure that information is gathered, completely
and in a timely manner.



Therefore, all Employees must report and
disclose all operational risk events or incidents arising in processes promptly, to both respective area heads and to the Operational
Risk Unit.



| | 14. | Environmental Protection
| | --- | ------------------------



The Bank recognizes that protecting the
environment is vital for society’s survival. Therefore, the Bank favors, in its business dealings, such measures as may seek
to protect the environment. Likewise, the Bank shall promote the efficient use of natural resources and recycling among its Employees.



| | 15. | 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.



| | 16. | Ethics Committee
| | --- | ----------------



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





16







The Ethics Committee consists of:



| | - | Chief Executive Officer (CEO)
| | - | -----------------------------

| | - | Executive Vice-President - Administration
(COO)
| | - | -----------------------------------------------

| | - | Executive Vice-President - Risk Management
| | - | ------------------------------------------

| | - | Vice-President - Human Resources
| | - | --------------------------------

| | - | Legal Counsel
| | - | -------------



The Heads of the Audit and Compliance Departments
shall partake in the Ethics Committee as independent observes, who shall be heard but are non-voting members, in order to assess
and oversee compliance with the Code of Ethics.



| | 17. | Approval of and Modifications to the Code of Ethics
| | --- | ---------------------------------------------------



The Code of Ethics should be approved by
the Board’s Nomination and Compensation Committee, who shall also evaluate such proposals for modifications and/or updates
as the Ethics Committee may deem to be pertinent.



| | 18. | Compliance with the Code of Ethics
| | --- | ----------------------------------



The Code of Ethics must be strictly adhered
to by the Directors of Bladex, Members of its Advisory Board and its Employees. The monitoring and compliance assurance of the
stipulations of the Code of Ethics shall be the responsibility of the Board’s Audit and Compliance Committee, based on the
reports submitted by the Internal Audit Area.



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 insider information, frauds or fraud attempts, accounting entries that do not comply
with generally accepted accounting principles, as well as any mysterious disappearance of funds or securities whenever they become
aware thereof. Employees may report these to the person(s) designated by the Bank for this purpose, following the procedures or
systems established thereto.



In the case of Bank employees, the sanctions
for Code of Ethics violations will be the joint responsibility of the Supervisors and the CEO, and in the case of the Directors,
the sanctions will be the responsibility of the Board's Audit and Compliance Committee. The Ethics Committee will be informed of
these sanctions.



Any violations of the Clauses contained
in the Code of Ethics shall have consequences for those involved in such violations, at all levels of the Organization. Any violation
of the Code of Ethics that implies a felony may end up in the courts after the corresponding competent authorities have been notified
thereof. Employees not complying with the Code of Ethics may also become the subject of internal disciplinary measures, as set
forth in Articles 40, 41 and 42 of the Employee Handbook.





17







| | 19. | Other Considerations
| | --- | --------------------



The Code of Ethics is part of the Bank’s
regulatory framework, together with the Discipline and Internal Rules and Regulations, 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
Heads of the Compliance or Audit Departments should be consulted.



Latest revision: July 13, 2015









18







FOREIGN TRADE BANK OF LATIN AMERICA,
INC. (“Bladex”)



SPECIAL STATEMENT FROM THE SENIOR
FINANCIAL EXECUTIVES REGARDING THE CODE OF ETHICS (THE “CODE”)



The Chief Executive Officer, the Executive
Vice President - Finance and the Vice President – Accounting, as Bladex senior financial executives (The “Senior Executives”),
herewith and hereby accept the contents of the Bladex Code of Ethics and agree to be bound by the additional dispositions contained
herein.



I.
This Special Statement for all Senior Executives at Bladex, has the purpose of encouraging:



| | Ø | Honest and ethical conduct, including
ethical management of actual or apparent conflict of interest between their personal and professional relationships;
| | - | ----------------------------------------------------------------------------------------------------------------------------------------------------------



| | Ø | 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.;
| | - | ----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------



| | Ø | Compliance with applicable laws and governmental
rules and regulations:
| | - | -----------------------------------------------------------------------



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



| | Ø | Responsibility for adhering to the Code.
| | - | ----------------------------------------



All Senior Executives shall adhere to high
ethical business standards and should be sensitive about situations that could result in actual or apparent conflicts of interest.
Bladex expects that its Senior 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.
Senior Executives should Ethically Manage Actual or Apparent Conflicts of Interests.



Summary.A “Conflict
of Interest” occurs when a Senior Executive’s private interest interferes with the interest of, or his or her service
at, Bladex. For example, a Senior Executive’s conflict of interest could arise if a Senior Executive or a member of his or
her family would receive improper personal benefits as a result of his or her position at Bladex.



All Senior Executives must ensure they
strictly follow the guidelines for Handling Conflicts of Interest, described in Clause 11 of the Code of Ethics and particularly
avoid the situations depicted there.



In situations involving a Senior Executive,
where the appearance or the potential of a conflict of interests is involved, but where the Senior Executive does not believe that
a significant conflict of interests exists, the Senior 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.





19







III. Disclosure and Compliance



| | Ø | All Senior Executives should get acquainted
with the disclosure and compliance requirements that are generally applicable to Bladex;
| | - | ------------------------------------------------------------------------------------------------------------------------------------



| | Ø | All Senior 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;
| | - | ------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------



| | Ø | All Senior Executives must, as far as
appropriate in their area of responsibility, consult with other Bladex Executives and Employees 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
| | - | ------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------



| | Ø | It is a responsibility of all Senior Executives
to encourage compliance with the standards and restrictions imposed by applicable laws, rules and regulations.
| | - | --------------------------------------------------------------------------------------------------------------------------------------------------------------



IV. Reports and Responsibilities



All Senior Executives shall:



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



| | Ø | Not take any retributive actions against
any other Bladex Senior Executive or Employee or their family members for reports about potential violations that were made in
good faith;
| | - | -----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------



| | Ø | 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 Senior Executive should be considered by the Audit and Compliance Committee.



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



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



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





20







| | Ø | 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 a recommendation for dismissing the Senior Executive;
| | - | ------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------



| | Ø | The Audit and Compliance Committee shall
be responsible for granting waivers to this Code, as may be appropriate; and
| | - | ---------------------------------------------------------------------------------------------------------------------



| | Ø | Any change or exception to this code 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 regulators or regulators of securities and stock markets where Bladex
is listed.



VI. Other Policies and Procedures



This Code shall be the only Ethics Code
adopted by Bladex, concerning the “Sarbanes-Oxley Act” of 2002 and the rules and forms 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.



IX. Internal Use



This Code is exclusively for the internal
use of Bladex and does not represent any admission, by or on 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/
    Rubens     V.     Amaral
    Jr. |  |                                   
|---------------------------------------- |  | ----------------------------------
|President & Chief Executive Officer      |  |                                   
|                                         |  |                                   
|                                         |  |                                   
|/s/
    Cristopher
    Schech            |  | /s/
    Kadhir
    Campos         
|Executive Vice President – Finance       |  | Senior Vice President – Accounting









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