Real Estate Legal Warranty Policy

1. Introduction

1.1. Policy Objective

The purpose of this Legal Warranty Policy is to provide clear, complete, and transparent information to buyers and owners of real estate properties built and/or sold by CONSTRUCTORA CARPOL S.A.S. (hereinafter, “CARPOL” or “the Builder”), regarding the scope, terms, conditions, exclusions, and applicable procedure for enforcing the legal warranty on their properties, in strict compliance with Colombia’s consumer protection regulations.

This document serves as an institutional reference tool, intended to protect the rights of real estate consumers, clearly define the developer’s obligations, and foster a relationship of trust, transparency, and good faith between CARPOL and its clients.

1.2. CONSTRUCTORA CARPOL's Commitment to Quality

CARPOL carries out its activities in the construction, development, and sale of real estate in accordance with standards of quality, suitability, and safety, using materials that meet the required technical specifications and engaging professionals and qualified personnel at every stage of the project.

The Construction Company recognizes the statutory warranty as a non-waivable obligation of public policy for which it is responsible, and undertakes to fully address, within the legal terms, any claim that falls within the scope of coverage provided by law.

1.3. Principles of Customer Service

• Legality: Every decision is made in accordance with current regulations, without compromising consumer rights.
• Good faith: Relationships with the owner are based on loyalty, transparency, and mutual cooperation.
• Dignified treatment and a substantive response: Every request, complaint, or claim receives a clear, timely, and well-reasoned response.
• Speed: The construction company processes applications within the legal timeframes and, when applicable, notifies applicants in writing of any justified extensions.
• Information: The owner receives accurate and sufficient information about the scope of their warranty and the maintenance obligations for which they are responsible.

2. Legal Framework

The legal warranty for properties delivered by CARPOL is governed by a comprehensive regulatory framework. The following is a simple explanation of the main applicable regulations:

2.1. Law 1480 of 2011 — Consumer Protection Act

It is the framework law for consumer protection in Colombia. It defines the legal warranty as the obligation of the manufacturer and the supplier to guarantee the quality, fitness for purpose, safety, and good condition of the goods they place on the market, without any additional consideration beyond the price (Art. 5, No. 5; Arts. 7 and 8). Article 8 expressly states that, for real property, the legal warranty covers the structural integrity of the building for ten (10) years and the finishes for one (1) year.

2.2. Decree No. 735 of 2013

It establishes the procedures for enforcing the legal warranty provided for in Law 1480 of 2011. Articles 13 and 14 specifically regulate the procedures, time limits, and consequences applicable to real property and the common areas of condominiums. Paragraph 3 of Article 13 reiterates that the warranty period for finishes and vital systems is one (1) year, and the warranty period for the structural stability of the building is ten (10) years.

2.3. Decree No. 1074 of 2015 — Consolidated Regulatory Decree for the Trade, Industry, and Tourism Sector

It compiles, without modification, the content of Decree 735 of 2013 (including, among others, Article 2.2.2.32.3.3 and related provisions). Therefore, when this policy refers to Articles 13 and 14 of Decree 735 of 2013, it should be understood that these are the provisions now codified in Decree 1074 of 2015 and that they are fully in force.

2.4. Colombian Civil Code

It applies in a complementary manner. Article 2060, paragraph 3 (the builder’s ten-year liability), and the provisions governing latent or redhibitory defects (Articles 1914 et seq.) strengthen the buyer’s protection against defects that compromise the stability or usability of the property.

2.5. Legal Warranty on Real Estate

The statutory warranty for real estate covers defects attributable to deficiencies in design, construction, materials, or installations carried out by the builder that affect the quality, suitability, or safety of the property and become apparent within the statutory time limits. It does not require a special agreement: it applies by law and cannot be waived.

2.6. Manufacturer's Liability

Pursuant to Article 10 of Law 1480 of 2011, liability under the statutory warranty rests jointly and severally with manufacturers and suppliers. To establish liability for failure to comply with the conditions of fitness for purpose and quality, it is sufficient to demonstrate the defect in the product, without prejudice to the grounds for exemption provided for in Article 16 of the same law (force majeure, unforeseeable circumstances, acts of a third party, or misuse by the consumer).

2.7. Consumer Rights

• To receive a property that meets the standards for quality, suitability, and safety.
• To enforce the statutory warranty through repair and, where applicable, replacement or a refund.
• To receive clear information and a substantive response to their complaints.
• To be protected against unfair terms in standard-form contracts (Articles 42 and 43 of Law 1480 of 2011).
• To bring a case before the ordinary courts or the Superintendency of Industry and Commerce (SIC) when deemed appropriate.

3. Scope

This policy applies to private real estate properties constructed and/or sold by CARPOL and delivered to the owner, as well as, where applicable, to the common areas of condominiums. By way of example, it includes:

• Apartments.
• Houses.
• Commercial spaces.
• Parking spaces.
• Deposits.
• Other private property delivered by the construction company as listed in the inventory and the delivery report.

3.1. Start of the Warranty

In accordance with Article 7 of Law 1480 of 2011, the term of the legal warranty begins on the date the property is actually delivered to the owner, regardless of whether or not the property is occupied from the first day. The date of delivery is the date stated in the delivery certificate signed by CARPOL and the owner.

Note on common property: In buildings subject to condominium ownership, the legal guarantee regarding common property must be requested by the condominium manager, in accordance with Article 14 of Decree 735 of 2013 and Article 50 of Law 675 of 2001.

4. Definitions

For the proper interpretation of this policy, the following definitions are adopted, based on Law 1480 of 2011, Law 400 of 1997, and standard construction practices:

5. Terms of the Statutory Warranty

5.1. What Is Covered

The legal warranty covers defects or failures attributable to deficiencies in design, construction, materials, or installations performed by CARPOL, provided that they become apparent within the legal timeframe and the owner complies with the conditions for upkeep and maintenance. It includes, among other things:

• Defects that compromise the stability, strength, or safety of the building's structure.
• Failures in the water, sewer, electrical, and gas systems (lifelines) installed by the construction company.
• Defects in finishes and non-structural elements included with the property.

5.2. What Is Not Covered

The warranty does not cover damage caused by misuse, lack of maintenance, modifications made by the owner or third parties, normal wear and tear of materials, force majeure or unforeseeable events, or circumstances beyond the Builder’s control (see Chapter 7, Exclusions).

5.3. Defects Covered by the Warranty

The warranty covers construction defects or flaws that affect the quality, suitability, or safety of the property, including hidden defects that become apparent within the statutory period applicable to each component.

5.4. Defects That Are the Owner's Responsibility to Repair

The owner, and not the warranty, is responsible for any damage that can be prevented or corrected through the periodic maintenance described in the owner’s manual. By way of example only, the following are considered the owner’s responsibility:

• Replacement of gaskets, cartridges, aerators, and other wear-and-tear parts for faucets and plumbing fixtures.
• Cleaning and unclogging traps, grates, drains, inspection chambers, and internal drainage systems affected by debris, grease, hair, foreign objects, or misuse.
• Re-sealing and replacement of silicone caulking or sealing materials in bathrooms, kitchens, sinks, countertops, windows, and other areas exposed to wear and tear or moisture.
• Periodic repainting of walls, ceilings, doorways, door frames, railings, and other surfaces that show signs of wear, discoloration, stains, or deterioration due to use or environmental factors.
• Maintenance, adjustment, lubrication, and calibration of doors, windows, hinges, plates, locks, sliding mechanisms, rollers, tracks, and other moving parts of metal or wood joinery.
• Preventive maintenance of woodwork, including the application of sealants, varnishes, paints, or protective products against moisture, sunlight, insects, or natural wear and tear.
• Cleaning and maintenance of windows, glass, aluminum profiles, drains, and water drainage channels.
• Replacement of light bulbs, light fixtures, switches, electrical outlets, batteries, remote controls, and other consumable or wear-and-tear items.
• Cleaning and maintenance of exhaust fans, range hoods, ventilation grilles, filters, and equipment provided with the property, in accordance with the manufacturers’ instructions.
• Periodic maintenance of surface waterproofing, visible expansion joints, and exposed seals, as recommended in the Owner's Manual or by the product manufacturer.
• Cleaning and maintenance of floors, siding, facades, roofs, balconies, terraces, and outdoor areas, preventing the buildup of water, dirt, or corrosive substances.
• Replacement of parts, accessories, or finishes affected by bumps, scratches, surface cracks, abrasion, impacts, overloading, improper use, or third-party modifications.
• Maintenance of gardens, planters, surface drainage, and irrigation systems, if any.
• Repair of damage caused by pets, moving, furniture installation, drilling, anchoring, remodeling, or any other work performed by the owner, occupants, or third parties.

In general, defects resulting from normal wear and tear due to the ordinary use of the property, a lack of regular maintenance, failure to follow the instructions in the Owner’s Manual, misuse of the facilities, or modifications, repairs, or alterations performed by anyone other than the builder or third parties authorized by the builder.

5.5. Damage resulting from normal use and natural wear and tear

Normal wear and tear resulting from ordinary use and the natural aging of materials (such as the gradual loss of paint luster, wear on seals, and microcracks caused by settling, among others) do not constitute defects attributable to the construction company and, therefore, are not covered by the warranty.

Technical Note on Settlement Cracks: During the building’s settlement period, cracks may appear in walls, ceilings, and floors; these are normal and do not pose a structural risk. Cracks will be addressed only once, provided that the owner has not applied finishes other than those originally installed on the surface and that the cracks are reported within the warranty period for finishes.

6. Warranty Periods

Warranty periods begin on the date of delivery of the property (Art. 7, Law 1480 of 2011). The law establishes two mandatory periods for real estate: ten (10) years for the structural integrity of the building and one (1) year for finishes and vital systems (Art. 8, Law 1480 of 2011; Art. 13, paragraph 3, Decree 735 of 2013).

Warranties that depend on the manufacturer: Household appliances, gas appliances, and specialized equipment (stoves, ovens, range hoods, water heaters, among others) are covered by the warranty provided directly by their manufacturer or supplier. The owner must file warranty claims directly with the manufacturer, keeping the relevant invoices and certificates.

Note on Locksmithing: For security reasons, CARPOL recommends that the owner replace the lock covers upon taking possession of the property. Once the locks have been tampered with or replaced by the owner, the developer will not be liable under the warranty for those components.

7. Warranty Exclusions

Damages arising from any of the following causes (Art. 16, Law 1480 of 2011) are not covered by the statutory warranty, as they are not attributable to the construction company; these include, but are not limited to:

7.1. Damages Caused by the Owner or Third Parties

• Blows, impacts, or punctures to finishes, glass, fixtures, or the structure.
• Renovations, remodeling, or changes to flooring, wall coverings, or finishes made by the owner.
• Installation of air conditioners, kitchens other than those provided, or other equipment on utility lines or walls.
• Electrical overloads caused by the use of power strips, extension cords, or the connection of commercial or industrial equipment.
• Damage caused by pets.
• Interference by unauthorized third parties or repairs not authorized by the construction company.
• Modification or alteration of structural elements (walls, slabs, columns) or of plumbing, sewer, electrical, or gas systems.

7.2. Damage Due to Lack of Maintenance or Improper Use

• Failure to perform the periodic maintenance specified in the owner's manual.
• Condensation-related moisture caused by a lack of adequate ventilation.
• Blockage of siphons, pipes, or drains caused by solid or semisolid waste.
• Misuse or use other than for residential purposes or as intended for the property.
• Normal wear and tear on materials due to use and the passage of time.

7.3. Damages Caused by External Events (Force Majeure or Unforeseeable Circumstances)

• Extraordinary natural events: earthquakes, floods, landslides.
• Fires not attributable to construction defects.
• Acts of terrorism, vandalism, or acts committed by third parties unrelated to the construction company.

7.4. Other Exclusions

• Finishes, equipment, or installations not delivered or installed by CARPOL.
• Defects caused by supplies, accessories, or equipment installed by the owner after delivery.
• Expiration of the warranty period applicable to the affected item.

Important: The basis for each exclusion is determined through a technical verification visit and is communicated to the owner in writing, with a detailed explanation and supporting evidence, in accordance with Article 3 of Decree 735 of 2013. Under no circumstances may these exclusions be interpreted as a limitation on or waiver of the minimum rights granted to consumers by law.

8. Owner's Responsibilities

The validity of the warranty is contingent upon the owner’s compliance with the following maintenance and use obligations. These obligations do not constitute a limitation of rights, but rather the duty of maintenance that the law recognizes as the responsibility of the consumer (paragraph of Article 24, Decree 735 of 2013):

• Follow the Owner's Manual and the usage and maintenance recommendations contained therein.
• Perform the periodic preventive and corrective maintenance for which you are responsible (see Chapters 9 and 19 and Appendices 5 and 6).
• Keep all invoices, certificates, and manuals for the equipment and items delivered, especially those related to the manufacturer's warranty.
• Allow for the necessary inspections and technical visits to verify and address complaints.
• Report defects in a timely manner and in writing, within the applicable warranty period.
• Do not alter the construction or apply different finishes to the original surfaces if doing so would prevent the defect from being verified.
• Do not alter any structural elements (walls, slabs, columns) or the water, plumbing, electrical, or gas systems.
• Maintain the property in a condition similar to that in which you received it, refraining from making any modifications or repairs on your own that would affect the coverage.

9. Owner's Manual

The Owner's Manual is an integral part of the warranty. It describes the property's features, recommendations for use, and maintenance responsibilities of the owner. Failure to follow the recommendations in the manual may result in the loss of coverage for the affected item. The manual covers, at a minimum:

9.1. Maintenance Frequency

Preventive maintenance is generally performed on an annual basis; some tasks are performed monthly (cleaning of traps, grates, outlets, and switches) or every four months (replacement of range hood filters). Details can be found in Appendix 5 (Schedule) and Appendix 6 (Maintenance Checklist).

9.2. Consequences of Failing to Perform Maintenance

A lack of regular maintenance may result in damage that will not be covered by the warranty and for which the owner will be solely responsible. When the cause of the damage is a failure to perform maintenance, the claim will be denied with an explanation following a technical inspection.

10. Delivery Inventory

The handover inventory provides a detailed list of the finishes, fixtures, and items included with the property and serves as proof of the condition in which the property was received.

10.1. What's Inside

Room by room, the inventory describes floors, walls, baseboards, ceilings, lighting, electrical and plumbing fixtures, woodwork, windows, furniture, and accessories, including their materials, colors, and sizes.

10.2. How to Fill It Out

This is completed at the time of delivery, in the presence of the owner or the owner’s authorized representative, by recording observations regarding the condition of each item and providing photographic evidence when appropriate.

10.3. What are the effects?

• Owner's signature: I hereby acknowledge receipt of the property and confirm that I am satisfied with what has been delivered, without this constituting a waiver of the warranty against hidden defects.
• Photo gallery: It documents the delivery status and facilitates the subsequent verification of claims.
• Notes: They document any outstanding issues or unusual circumstances noted at the time of delivery.
• Acceptance: It sets the date from which the statutory warranty period begins.

11. Procedure for Requesting a Guarantee

The procedure complies with Article 13 of Decree 735 of 2013. The written report is mandatory and constitutes a prerequisite for the construction company’s obligation to take effect.

11.1. Customer Service Channels

• The PQRS form is available on the website (under the “After-Sales Warranty” option).
• The construction company's official email address.
• Written communication filed with CARPOL's offices.

11.2. Minimum Information Required for the Application

• Property identification (project and house/apartment number).
• Owner's name and ID number; contact phone number.
• A clear description of the defect, including its location.
• Date the damage was detected.
• Photos or video of the defect, if possible.
• Document proving ownership or authorization (deed, purchase agreement, or power of attorney).

11.3. Stages of the Process

• Filing and acknowledgment of receipt of the claim.
• Technical verification visit within the next 5 business days.
• Technical concept and a well-reasoned written response.
• Repair, replacement, or refund, as appropriate.
• Case closed with documentation of the work performed.

Recommendation: Do not make any changes to the affected area before the service visit. Modifying the defect may make diagnosis more difficult and void the warranty.

12. Technical Visit Procedure

12.1. Programming

The verification visit is scheduled within 5 business days of the filing of the claim (Art. 13, Decree 735 of 2013) or, as coordinated with the property owner, on a date and time within business hours.

12.2. Access to the Property

The property owner must allow CARPOL technical staff access to the property. If the owner authorizes a third party to handle the visit, the owner must provide that person’s full name, ID number, and phone number.

12.3. Rescheduling and Absence of the Owner

If the owner does not grant access or is not present on the agreed-upon date, the visit will be rescheduled once. If the defect cannot be verified due to a cause attributable to the owner, the terms applicable to the construction company are suspended until access is granted.

12.4. Record and Visit Report

A report is prepared for each visit, documenting the subject of the complaint, the findings, the preliminary technical assessment, and the signatures of the parties.

13. Response Times

The timeframes are governed by Article 13 of Decree 735 of 2013, which distinguishes between finishes/vital elements and structural stability:

Complex cases and extensions: In the rare event that it is not possible to resolve the matter within the specified timeframes, CARPOL will notify the owner in writing, prior to the expiration of the deadline, of the reasons for the delay and the reasonable timeframe for a response. In structural matters, the extension applies for an equal period, subject to written notification.

Recurrence of the failure: If the defect recurs after the repair, the consumer may choose between a new repair, replacement of the affected finish or vital component, or payment of an amount equivalent to its value (Art. 13, Decree 735 of 2013).

14. Manufacturer Warranties

Some equipment and items included with the property come with their own warranty provided by the manufacturer or supplier, which is separate from the construction warranty provided by CARPOL. In these cases, the warranty claim must be filed directly with the manufacturer; be sure to keep the invoice and the corresponding certificate. This applies, among other things, to:

• Elevators.
• Water pumps and pressure equipment.
• Intercoms and communication systems.
• Specialized electrical equipment.
• Home appliances.
• Water heaters.
• Stoves, ovens, and range hoods.
• Other specialized equipment.

Claims or warranty issues regarding the gas installation must be handled directly with the service provider. This is without prejudice to CARPOL’s liability for the proper initial installation of the main lines within one (1) year.

15. Common Areas

In buildings subject to the condominium regime, the statutory warranty covering common property is governed by Article 14 of Decree 735 of 2013.

15.1. Who Is Liable?

CARPOL is liable for construction defects in common areas under the same terms and time limits that apply to private areas (10 years for the structural integrity of the building and 1 year for finishes and critical systems).

15.2. How They Should Be Processed

The application for a guarantee on common property must be filed by the condominium manager, in accordance with Article 50, paragraph 1, of Law 675 of 2001. The procedure and terms are the same as those set forth in Article 13 of Decree 735 of 2013.

15.3. The Role of the Co-Ownership Association, the Administrator, and the Board of Directors

• Administrator: Legal representative of the condominium association; files and handles claims regarding common property and grants access for technical inspections.
• Board of Directors: It supports the prioritization and tracking of claims regarding common property.
• Meeting of Co-owners: The highest authority responsible for making decisions regarding common property in accordance with the condominium regulations.

16. Protection of Personal Data

CARPOL processes the personal data provided during the warranty process in compliance with Law 1581 of 2012, Decree 1377 of 2013, and any other regulations that amend or supplement them.

• The data is used exclusively to manage, process, and respond to warranty or after-sales service requests.
• The information is stored and protected using reasonable technical and administrative measures that ensure its security, confidentiality, and integrity.
• Data is not shared with third parties without prior authorization, unless required by law or by a competent authority.
• The data subject may exercise their rights of access, update, correction, deletion, and revocation at any time, in accordance with the Construction Company’s Personal Data Processing Policy.

17. Official Customer Service Channels

The owner can contact CARPOL through the following official channels:

18. Recommendations for the Owner

To keep your property in top condition and ensure that your warranty remains valid, CARPOL recommends:

• Read and keep the Owner's Manual, and share it with your immediate family.
• Ventilate your home daily and open the windows in the morning to prevent moisture from condensation.
• Perform routine maintenance on the recommended dates (Appendices 5 and 6).
• Use mild cleaning products and avoid acids, solvents, and abrasives on finishes and appliances.
• Do not overload electrical circuits or use power strips or extension cords on a permanent basis.
• Do not pour solid waste, grease, or corrosive substances down the drains.
• Do not alter structural walls or utility lines; consult the technical department before undertaking any renovations.
• Keep invoices, certificates, and manuals for the equipment that was delivered.
• Report any defects in a timely manner and in writing within the warranty period.
• Do not disturb the affected area before the technical inspection.