Exhibit
11.1











CODE
OF ETHICS





UPDATED:
July 2009


Approved
by the Nomination and Compensation Committee in its July 13, 2009 meeting, as
stated in the corresponding minutes.





INTRODUCTION





The set
of ethical principles adopted by the Foreign Trade Bank of Latin America,
Inc (“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 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 solid 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 need to be regarded with guidelines
for carrying out its business,To this extent, the values of the Bank:
Commitment, Humility, Excellence, Respect and Integrity, constitute the
foundations of organizational culture and are the framework for the individual
and collective behavior of all collaborators.





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 promote and strengthen an
organizational culture focused on values and showing and emphasizing to all of
the collaborators 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, and Members
of the Advisory Board, Suppliers and Collaborators.  At the same time,
each supervisor shall guarantee that his/her subordinates participate
exclusively in those assignments and tasks for which they possess the required
knowledge abilities and expertise.


2


1.
Objectives





Bladex
Code of Ethics pursues the following objectives:





Ø
            To
      act as 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 Employees, Board of Directors,
      and Staff.


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.


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


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





Under no
circumstances may personal conduct interfere with organization values and
interests.





All
Bladex’s staff members are responsible for ensuring that the Bank’s values and
principles are honored at all times, within as well as without the
organization.





3




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, humility, 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 attitude that
honorable persons with solid 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
collaborators 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 a head 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 and our clients’ expectations.


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





Respect:





·
            Be
      considered of others


·
            Foster
      harmony in interpersonal
relationships.





Integrity:





·
            Be
      transparent, honest, professional and
reliable.


·
            Promote
      and enforce standars for appropiate
behavior


·
            Have
      zero tolerance for fraud or
corruption.





Due to
their position of trust, the personal finances of all the Bank’s collaborator
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.


4


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





Any
behaviors 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
      proprietor interest.  If, for any reason and under no
      preferential treatment conditions, the aforementioned transactions are
      performed, the Bank’s Head Compliance Officer   shall be
      informed in writing.


-
            The
      usage of 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 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 collaborators 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 USD200.00 (except for
      Invitations regarding food and beverages), which could influence objective
      decision making.


-
            Using
      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 that discriminatory, harassing or intimating attitude or behavior
      towards collaborators.


-
            The
      usage of equipment or facilities assigned for the performance of his/her
      duties for personal purposes.


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


5


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


-
            Infringement
      of established policies, norms and procedures in detriment of the
      organization.





5.  Managing
Information





Behavior
shall always guarantee the best interests of the Bank, maintaining
confidentiality of its business and operations, as well as the confidentiality
of its 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 classified and privileged 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.
              Privileged 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.





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





Ø
            The
      company’s strategic plan.




§
            Expected
      financial results.




§
            Future
      expected earning per share.




§
            Any
      decision related to dividend
payment.




Ø
            Possible
      merges, acquisitions and/or strategic
alliances.




Ø
            Penal
      processes against the company.




Ø
            Development
      of important products or
services.


6


Ø
            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 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 until it has
      been disclosed through public media and/or media previously established
      for this purpose.  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.
              Confidential
      and privileged information
management




5.2.1
Information received from clients




a.
                Thoseemployees
      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:




Based on
the above, it is prohibited to use any confidential and privileged information
for illegitimate business purposes, for purposes different from those for which
it was requested or for personal benefit or of third parties.




Directors,
Members of the Advisory Board, employees and the Bank itself 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, regular or occasional access to relevant information concerning a
Bladex’s client, will not be allowed to perform, promote or protect on his/her
own behalf or that of a third party, directly or indirectly, any of the
following behaviors:


7


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




Þ
            Disclose
      non-public material or information pertaining to 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.




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




Þ
            Grant
      access, to whom is not entitled to it, to non-public material or
      information pertaining to 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 to section No.6 Insider Trading):




5.2.3
              Information
      provided by Bladex to its employees, directors, 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’s Disclosure Committee shall previously review and evaluate all
      confidential and/or privileged information related to Bladex intended for
      disclosure to employees, directors, clients, investors, purveyors,
      outsourcing purveyors or competent
authorities.


8


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 systems of its computer 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 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.   
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, 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 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, Member of the Advisory Board, Officer or employee, and the Bank
itself, may be exposed to civil lawsuits or penalties as a result of any breach
of regulations applicable to the handing of confidential and privileged
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.


9


6.1.         
Window period:




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 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 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 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.




Directors,
Members of the Advisory Board, Officers and employees shall submit 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, Member of the Advisory Board or Officer, including the
      CEO, notification should be made to the President of the Board of
      Directors of the Bank with a copy to the Shareholder
      Department.




·
            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 Bank
      with a copy to the Shareholder
    Department.




·
            If
      a Bank collaborator, 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.


10


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 fort 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.





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
sale/purchase of 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 by assumed by the individual.





The Audit
and Compliance Committee of the Board of Directors shall determine the severity
of the infringement and shall apply the disciplinary measures it deems
appropriate.





6.2.         
“Rule” 10-b5-1 of the Securities and Exchange Commission




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





6.3.          
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 contained 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 standing order.





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.


11


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 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 that has 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 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.
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.





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 Banks as a whole, in order to avoid
any legal problems that could be caused for the Bank.





10.
Interpersonal relationships in 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, having a solid character
should be distinctive trait of each of its Employees, so that the interpersonal
relation, with regards to dealing with Customers and labor relations at the Bank
do reflect the highest levels and standard of trustworthiness.


12


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 Banks
respects the right to privacy of its collaborator, therefore, matters of
personal nature concerning current or past collaborator 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 individuals differences as well as for opinions that are
      contrary to their own.


·
            Humility
      on accepting and receiving feedback from
others.


·
            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 established policies, rules and procedures in the
      organization.





11.
Handling Conflicts of Interest





The
existence of any kind of personal interest in a transaction, work relation 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 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.


13


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 from, or offer 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.


·
            To
      use their condition as a Bladex Collaborator 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, 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,
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 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.





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.


14


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 the 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
            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.





15.
Ethics Committee


The
Ethics Committee 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.





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, Members of the Advisory Board and employees 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.


15


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 designated by
the Bank for this purpose, following the procedures or systems established for
it.





In the
case of Bank collaborators, 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 constitutes 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 Comptroller should be
consulted.





Last
revision:  July 13, 2009


16


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





ADENDA (THE “ADENDA”) TO THE
CODE OF ETHICS (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
dispositions contained herein.





I. 
This Addenda applies to all Top Executives at Bladex, with 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 Top
Executives shall adhere to high ethical business standards and should be
sensitive about situations that could result in actual or apparent conflict of
interest.  Bladex expects that its Top 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
“Conflict 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 Top Executive’s conflict of interest could arise if a Top Executive or a
member of his family would receive improper personal benefits as a result of his
or her position at Bladex.





All Top
Executive must ensure the 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.


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





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


Ø
            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;


Ø
            All
      Top Executives must, as far as appropriate in their area of
      responsibility, consult with other Bladex Executives and Collaborators 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 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:





Ø
            Once
      this code has been adopted (or if applicable later on, upon becoming a Top
      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 Top Executive or
      Collaborator 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
Top Executive should be considered by the Audit and Compliance
Committee.





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


18


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;


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 the recommendation for dismissing the Top
      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, 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.





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.


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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 RIVERAChief
      Executive Officer





/s/
      CHRISTOPHER SCHECH/s/
      EDUARDO SÁNCHEZSenior
      Vice President – CFO
                    
                    Assistant
      Vice President – Main
Accountant


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