Grupo Cibest Director Luis Fernando Restrepo Echavarria Adds Pension Fund Units Through Voluntary Contribution

Details of the Pension Fund Transaction and Structure

The transaction disclosed in the amended report involves the acquisition of units within Grupo Cibest's institutional voluntary pension fund, an investment vehicle sponsored by the company and managed by an independent third-party administrator. On July 16, 2026, director Restrepo Echavarria made a voluntary cash contribution that resulted in the crediting of 492.52 units to his pension account. The fund operates on a unitized structure, with each unit carrying a price determined by the fund's net asset value on the transaction date.

The price per unit on July 16, 2026, was Colombian Pesos 26,276.51, equivalent to approximately $8.13 using the contemporaneous exchange rate of 3,233.91 pesos per U.S. dollar. The units themselves do not represent direct ownership of a fixed number of shares; rather, they provide an economic interest in the fund's underlying holdings. As of the transaction, the reporting person's units carried an economic attribution to 41,555.57 common and preferred shares of Grupo Cibest, though the precise share count attributable to each unit will be determined only upon withdrawal from the fund.

Governance Framework of the Voluntary Pension Fund

The institutional voluntary pension fund operates under governance provisions that insulate it from direct control by individual investors. The disclosure specifies that the reporting person holds no voting rights or investment discretion regarding the assets held within the fund, with all investment decisions and fund management delegated to the independent third-party administrator. This structure protects the fund from becoming a vehicle for concentrated insider influence over company assets while preserving tax-advantaged retirement savings benefits for participants.

Unit contributions to the fund are made solely through voluntary cash payments and are not subject to fixed or negotiated pricing mechanisms. Instead, the price of each unit fluctuates based on the fund's net asset value, ensuring that all participants receive fair value consistent with the fund's market performance. Upon withdrawal, distributions are paid exclusively in cash based on the value of the fund on the withdrawal date, rather than through in-kind delivery of shares. This cash-based redemption structure provides liquidity and simplifies tax and accounting treatment for participants.

Amendment Rationale and Clerical Correction Process

The amended report filed on July 23, 2026, addressed a clerical error identified in the original Form 4 submission made on July 17, 2026. The original filing contained an incorrect calculation of the number of derivative securities acquired and beneficially owned following the pension fund contribution. The amended filing corrected column 5, which reports securities acquired, and column 9, which reports total beneficial ownership following the transaction, bringing the reported figures into alignment with the actual contribution amount.

The correction process reflects standard SEC compliance procedures for insider transaction reporting. Insiders and their representatives must file initial reports of beneficial ownership changes within two business days of the transaction, and amended filings may be submitted to correct errors or omissions discovered after the initial submission. The amendment does not indicate any substantive change to the economic substance of the transaction or the reporting person's beneficial ownership position; rather, it reflects a mathematical correction to ensure accurate disclosure of the transaction details.

Economic Interest and Underlying Share Attribution

The pension fund units provide Restrepo Echavarria with an indirect beneficial ownership interest in Grupo Cibest securities. The fund's investment portfolio consists primarily of Grupo Cibest common and preferred shares, supplemented by a small cash component for liquidity management. The economically attributable share count of 41,555.57 represents the number of Grupo Cibest shares that would be deliverable to the reporting person upon complete liquidation and redemption of his pension fund units at their then-current net asset value.

However, the actual number of shares per unit remains variable and cannot be precisely calculated until the reporting person elects to withdraw from the fund. This structure reflects the unitized nature of pension fund investments, wherein the value of holdings fluctuates with underlying asset prices rather than maintaining a fixed share equivalence. The approximately $8.13 unit price as of July 16, 2026, implies a fund net asset value that supports the indirect economic interest in the disclosed share count, but future unit prices will shift as the fund's equity and cash holdings appreciate or depreciate.

Director Status and Reporting Obligations

Luis Fernando Restrepo Echavarria is identified in the disclosure as a director of Grupo Cibest S.A., a status that triggers mandatory insider trading reporting obligations under Section 16 of the Securities Exchange Act of 1934. As a director, he is required to report all changes in beneficial ownership of company securities within the prescribed timeframe, including indirect holdings through pension funds and other investment vehicles. The disclosure confirms his director status through the applicable checkbox marking on the amended report.

The reporting person's address is listed as Carrera 48 Number 26-85 in Medellín, Colombia, reflecting the company's Colombian incorporation and the prevalence of Colombian nationals among its insider shareholders and board members. This geographic detail underscores Grupo Cibest's operational and ownership base within Colombia while highlighting the company's listing on the New York Stock Exchange as an American depositary share vehicle accessible to U.S. investors.

Filing Status and Amendment Authority

The amended report was executed by Maria Fernanda Valencia Tafur, identified as attorney-in-fact for the reporting person. This delegation of signature authority to a legal representative is a common practice in insider transaction filings, particularly when the reporting person resides outside the United States. The attorney-in-fact certification confirms that the information contained in the amended filing is accurate and that any intentional misstatements or omissions would constitute federal criminal violations under relevant securities laws.

The amended filing bears a submission date of July 23, 2026, six days after the original report's July 17 filing date. The original transaction itself occurred on July 16, 2026, meeting the requirement that initial reports be filed within two business days. The amendment corrected errors that did not involve delays in reporting the transaction itself but rather computational accuracy in the subsequent disclosure document, a distinction important for evaluating compliance with insider trading rules.

Grupo Cibest Business Context and Market Position

Grupo Cibest S.A. operates as a financial services company with a Colombian base and New York Stock Exchange listing. The company's organizational structure includes provisions for retirement and pension benefits administered through institutional funds that invest in company equity securities. The decision to offer such voluntary pension funds reflects a commitment to employee and insider compensation structures that align participant interests with company performance while providing tax-advantaged savings vehicles.

The company's dual listing framework, operating as a Colombian corporation with American depositary shares tradable on the NYSE under ticker CIB, exposes it to regulatory requirements from both Colombian and U.S. securities authorities. The insider transaction reporting regime under Section 16 of the U.S. Securities Exchange Act applies to all beneficial owners and officers of NYSE-listed securities, regardless of the issuer's home jurisdiction. This regulatory framework ensures that U.S. investors receive timely disclosure of significant insider transactions affecting the company's equity securities.

Pension Fund Unit Valuation and Currency Considerations

The valuation of pension fund units involves currency conversion between Colombian Pesos and U.S. Dollars, reflecting Grupo Cibest's cross-border operations and the NYSE listing of its securities in dollars. The disclosed unit price of COP 26,276.51 on July 16, 2026, translates to approximately $8.13 using the contemporaneous exchange rate of 3,233.91 pesos per dollar. This exchange rate figure is material to investors seeking to understand the dollar-equivalent value of insider transactions in Colombian-domiciled financial instruments.

Currency fluctuations between the peso and the dollar directly affect the reported dollar value of pension fund transactions. The amended report's disclosure of both the peso-denominated unit price and the dollar-equivalent amount provides transparency for investors who may evaluate insider trading activity in USD terms. The specific exchange rate disclosed in the footnotes enables independent verification of the dollar conversion and supports the accuracy of the insider transaction report as submitted to the SEC.

Investor Monitoring and Beneficial Ownership Tracking

Investors tracking insider activity at Grupo Cibest should note that pension fund units constitute reportable beneficial ownership even though they provide no direct voting control or investment discretion. The reported 492.52 units acquired in a single transaction represent a meaningful addition to the reporting person's Grupo Cibest holdings, with economic exposure to tens of thousands of underlying shares. Future amendments or corrections to insider filings may be posted to the SEC EDGAR system as insiders discover and correct errors in their initial disclosures.

The amended report emphasizes the importance of reviewing correction notices filed after initial insider transaction reports, as these amendments often provide more accurate information regarding the ultimate economic impact of insider transactions. Investors researching Restrepo Echavarria's beneficial ownership history should cross-reference both the original July 17, 2026, filing and this subsequent July 23, 2026, amendment to ensure they are working with the corrected transaction figures. Such attention to detail is particularly important when evaluating patterns of insider accumulation or disposition of company securities.