Bernardo Navarro, ethics agreement with the Department of State, nominee for Ambassador to the Republic of Peru (October 31, 2025)

Summary

A letter from Bernardo Navarro, nominee for Ambassador to the Republic of Peru, to Steven F. Fabry, Designated Agency Ethics Official in the Office of the Legal Adviser at the Department of State, on ethics undertakings. Navarro describes the steps he will take to avoid any actual or apparent conflict of interest if confirmed. Section 1, General Commitments, states that under 18 U.S.C. § 208(a) he will not participate personally and substantially in any particular matter in which he or a person whose interests are imputed to him has a financial interest, unless he first obtains a written waiver or qualifies for a regulatory exemption under 18 U.S.C. § 208(b)(2). The letter also lists company holdings.

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“Bernardo Navarro, ethics agreement with the Department of State, nominee for Ambassador to the Republic of Peru (October 31, 2025).” Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/bernardo-navarro-ethics-agreement-with-the-department-of-state-nominee-a0a009bcad/, SHA-256 d2e243bfbf2956561d25ff767958be140158f5649308dc0dcf1b454a8cddb237.

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Date: 0 -
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Steven F. Fabry
Designated Agency Ethics Official
Office of the Legal Adviser
Department of State

Re: Ethics Unde1iakings

Dear Mr. Fabry:

The purpose of this letter is to describe the steps that I will take to avoid any actual or
apparent conflict of interest in the event that I am confirmed for the position of Ambassador to
the Republic of Peru. It is my responsibility to understand and comply with commitments
outlined in this agreement.

SECTION 1 - GENERAL COMMITMENTS

As required by the criminal conflicts of interest law at 18 U.S.C. § 208(a), I will not
paiiicipate personally and substantially in any patiicular matter in which I know that I have a
financial interest directly and predictably affected by the matter, or in which I know that a person
whose interests are imputed to me has a financial interest directly and predictably affected by the
paiiiculai· matter, unless I first obtain a written waiver, pursuant to 18 U.S.C. § 208(b)(l), or
qualify for a regulat01y exemption, pursuant to 18 U.S.C. § 208(b)(2). I understand that the
interests of the following persons are imputed to me:

• Any spouse or minor child of mine;
• Any general paiiner of a partnership in which I am a limited or general paiiner;
• Any organization in which I serve as an officer, director, trustee, general paiiner,
or employee, even if uncompensated; and
• Any person or organization with which I am negotiating or have an arrangement
concerning prospective employment.

In addition, I will recuse myself from paiiicipation on a case-by-case basis in any
paiiicular matter involving specific pa1iies in which I determine that a reasonable person with
knowledge of the relevant facts would question my impaiiiality in that matter, unless I am first
authorized to paiiicipate, pursuant to the impaiiiality regulations at 5 C.F.R. Part 2635, Subpaii
E.

In the event that an actual or potential conflict of interest arises during my appointment, I
will consult with an agency ethics official and take the measures necessary to resolve the
conflict, such as recusal from the particular matter or divestiture of an asset.
I understand that a heightened prospect of a conflict of interest could exist as to
companies that maintain a presence in the Republic of Peru, because they may be more likely
than other companies to seek official assistance from or make contact with the Embassy or
otherwise be affected by policies and engagement implemented by the Embassy. I will remain
alert to the possible need for recusal where appropriate.

I have a managed account, and I will direct the account manager to obtain my prior
approval on a case-by-case basis for the purchase of any assets other than cash, cash equivalents,
investment funds that qualify for the regulatory exemption for diversified mutual funds and unit
investment trusts at 5 C.F.R. § 2640.201(a), obligations of the United States, or municipal
bonds. I will monitor whether the account manager is following this direction regarding prior
approval.

I will receive a live ethics briefing from a member of the ethics office after my
confirmation but not later than 15 days after my appointment pursuant to the ethics program
regulation at 5 C.F.R. § 2638.305. Within 90 days of my confirmation, I will submit my
Certification of Ethics Agreement Compliance which documents my compliance with this ethics
agreement.

I will not modify this ethics agreement without your approval and the approval of the
U.S. Office of Government Ethics (OGE) pursuant to the ethics agreement requirements
contained in the financial disclosure regulation at 5 C.F.R. § 2634.803(a)(4).
SECTION 2 - BENWORTH CAPITAL PARTNERS PR LLC

My spouse and I co-own Bentworth Capital Partners PR LLC and my spouse serves as
Chief Executive Officer. Upon confirmation, I will resign from my position with Benworth
Capital Partners PR LLC. We will continue to have an equity interest in it, but I will not provide
services material to the production of income. Instead, I will only receive passive investment
income from it. I will not participate personally and substantially in any particular matter that to
my knowledge has a direct and predictable effect on the financial interests of Benworth Capital
Partners PR LLC, unless I first obtain a written waiver, pursuant to 18 U.S.C. § 208(b)(l).

SECTION 3 -REAL ESTATE SALES FORCE INC.

Upon confirmation, I will terminate my consulting agreement with Real Estate Sales
Force Inc. Pursuant to the impaiiiality regulation at 5 C.F.R. § 2635.502, for a period of one year
after I terminated my agreement, I will not paiiicipate personally and substantially in any
particular matter involving specific paiiies in which I know Real Estate Sales Force Inc. is a
paiiy or represents a party, unless I am first authorized to paiiicipate, pursuant to 5 C.F.R.
§ 2635.502(d). In addition, I will not paiiicipate personally and substantially in any patiicular
matter involving specific paiiies in which I know a former client of mine is a paiiy or represents
a paiiy for a period of one year after I last provided service to that client, unless I am first
authorized to paiiicipate, pursuant to 5 C.F.R. § 2635.502(d).
SECTION 4 - FAMILY TRUST #2
I am the trustee of Family Trust #2, which I established subsequent to filing my OGE
Form 278e. I will retain my position as a trustee of Family Trust #2. I will not receive any fees
for the services that I provide as a trustee during my appointment to the position of Ambassador.
I will not participate personally and substantially in any particular matter that to my knowledge
has a direct and predictable effect on the financial interests of Family Trust #2, unless I first
obtain a written waiver, pursuant to 18 U.S.C. § 208(b)(l), or qualify for a regulatory exemption,
pursuant to 18 U.S.C. § 208(b)(2).
SECTION 5 RESIGNATIONS
A. RESIGNATIONS- SPOUSE AND MR. NAVARRO WILL RETAIN EQUITY INTERESTS

Upon confirmation, I will resign from my positions with the following entities:

• BenFam Holdings PR LLC
• Benworth Financial LLC
• Benworth Management LLC
• Benworth Opportunity Fund LLC
• Benwo1ih Opp01iunity Fund 2 LLC
• Gasparilla Breeze LLC
• Placida Management LLC
• 291 Holdings LLC

My spouse and I will continue to have an equity interest in these entities, but I will not provide
services material to the production of income. Instead, I will only receive passive investment
income from them. I will not pmiicipate personally and substantially in any pmiicular matter that
to my knowledge has a direct and predictable effect on the financial interests of these entities,
unless I first obtain a written waiver, pursuant to 18 U.S.C. § 208(b)(l), or qualify for a
regulatory exemption, pursuant to 18 U.S.C. § 208(b)(2).

B. RESIGNATIONS AND RETENTION OF EQUITY INTERESTS

Upon confirmation, I will resign from my positions with the following entities:

• BenFam Holdings LLC
• B.E.N. Development Corp.
• BEN NAV, LLC
• Biltmore Investments LLC
• Benw01ih Capital Pminers, LLC
• Benw01ih Trustee Services, LLC

I will continue to have an equity interest in these entities, but I will not provide services material
to the production of income. Instead, I will only receive passive investment income from it. I will
not patiicipate personally and substantially in any patiicular matter that to my knowledge has a
direct and predictable effect on the entity, or its underlying holdings, unless I first obtain a
written waiver, pursuant to 18 U.S.C. § 208(b)(l), or qualify for a regulatory exemption,
pursuant to 18 U.S.C. § 208(b)(2).

C. PREVIOUS RESIGNATIONS WITH NO RETENTION OF EQUITY

I previously resigned my position as manager of Chateau Dorado LLC and 11 DBE
Holdings LLC. Pursuant to the impartiality regulation at 5 C.F.R. § 2635.502, for a period of one
year after my resignation from each of these entities, I will not participate personally and
substantially in any patiicular matter involving specific patties in which I know that entity is a
pmiy or represents a pmiy, unless I am first authorized to pmiicipate, pursuant to 5 C.F.R. §
2635.502(d).

SECTION 6 DIVESTITURES

I will divest my equity interests in the entities listed in APPENDIX A as soon as
practicable but not later than 90 days after my confirmation. With regard to each of these entities,
I will not pmiicipate personally and substantially in any pmiicular matter that to my knowledge
has a direct and predictable effect on the financial interests of the entity until I have divested it,
unless I first obtain a written waiver, pursuant to 18 U.S.C. § 208(b)(l), or qualify for a
regulatory exemption, pursuant to 18 U.S.C. § 208(b)(2). I have verified that I will be able to
carry out the divestitures within the timeframe described above.

In addition, as soon as practicable but not later than 90 days after my confirmation, I will
divest my interest Coatue Opportunity Fund II LP. I will not participate personally and
substantially in any pmiicular matter that to my knowledge has a direct and predictable effect on
the financial interests of Coatue Opp01iunity Fund II LP or its underlying holdings until I have
divested it, unless I first obtain a written waiver, pursuant to 18 U.S.C. § 208(b)(l), or qualify for
a regulatory exemption, pursuant to 18 U.S.C. § 208(b)(2). I have verified that I will be able to
carry out the divestitures within the timeframe described above.

I understand that I may be eligible to request a Ce1iificate of Divestiture for qualifying
assets and that a Ce1iificate of Divestiture is effective only if obtained prior to divestiture.
Regardless of whether I receive a Certificate of Divestiture, I will ensure that all divestitures
discussed in this agreement occur within the agreed upon timeframes and that all proceeds are
invested in non-conflicting assets. I understand that I must submit my request for a Ce1iificate of
Divestiture to allow for adequate time for OGE to process the Certificate of Divestiture, and in
order to divest assets within the agreed upon timeframe.

I (including my spouse and minor children if applicable) will not repurchase any asset I
was required to divest without consulting with my agency ethics official and the U.S. Office of
Government Ethics.
SECTION 7 - PUBLIC POSTING

I have been advised that this ethics agreement and the Certification of Ethics Agreement
Compliance will be posted publicly, consistent with the public information law at 5 U.S.C.
§ 552, on the website of the U.S. Office of Government Ethics with ethics agreements of other
presidential nominees who file public financial d • c osure rep01is.
APPENDIX A

Air Products & Chemicals Inc (APD)
Alphabet Inc (GOOGL)
Alphabet Inc. Class C Capital Stock
(GOOG)
Amazon.com Inc. (AMZN)
American Express Company (AXP)
Apple Inc. (AAPL)
Bank of America Corp. (BAC)
Boeing CO (BA)
Capital One Financial Corp (COF)
Choice Hotels International Inc. (CHH)
Chubb LTD (CB)
Coca Cola Company (KO)
Conoco Phillips (COP)
Danaher Corporation (DHR)
Dell Technologies Inc. (DELL)
Eaton Corporation (ETN)
Emerson Electric CO (EMR)
Equifax (EFX)
Estee Lauder Companies Inc (EL)
GE Healthcare Technologies Inc (GEHC)
General Dynamics Corp. (GD)
Halliburton Company (HAL)
Honeywell Intl (HON)
Johnson & Johnson (JNJ)
Johnson Controls International PLC (JCI)
L3Harris Technologies Inc. (LHX)
LINDE PLC (LIN)
Mastercard Incorporated (MA)
Meta Platforms Inc Class A (META)
Microsoft Corp (MSFT)
Nike Inc. (NKE)
Northrop Grumman Corp (NOC)
Oracle Corporation (ORCL
Paypal Holdings Inc (PYPL)
Rollins Inc (ROL)
RTX Corporation (RTX)
UnitedHealth Group Inc (UNH)
Visa Inc (V)
Walt Disney CO (DIS)
Wells Fargo (WFC)

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