Exhibit 25.1

SECURITIES AND EXCHANGE COMMISSION 

Washington, D.C. 20549

FORM T-1

STATEMENT OF ELIGIBILITY 

UNDER THE TRUST INDENTURE ACT OF 1939 

OF A CORPORATION DESIGNATED TO ACT AS TRUSTEE

☐    CHECK IF AN APPLICATION TO DETERMINE ELIGIBILITY OF A TRUSTEE PURSUANT TO 

SECTION 305(b)(2)

THE BANK OF NEW YORK MELLON 

(Exact name of trustee as specified in its charter)

New York	13-5160382
(State of incorporation	(I.R.S. employer
if not a U.S. national bank)	identification no.)

240 Greenwich Street, Floor 7 East, New York, N.Y.	10286
(Address of principal executive offices)	(Zip code)

Ecopetrol S.A.

(Exact name of obligors as specified in their charters)

Republic of Colombia	Not applicable
(State or other jurisdiction of	(I.R.S. employer
incorporation or organization)	identification no.)

Ecopetrol S.A. 

Carrera 13 No. 36 – 24 

Bogota, Republic of Colombia 

(57-601) 234-4000 

(Address of registrants’ principal executive offices)

Debt securities 

(Title of the indenture securities) 

 1. General information. Furnish the following information as to the Trustee:

(a) Name and address of each examining or supervising authority to which it is subject.

Name	Address
Superintendent of Banks of the State of New York	One State Street, New York, N.Y. 10004, and One Commerce Plaza, Albany, N.Y. 12257
Federal Reserve Bank of New York	33 Liberty Street, New York, N.Y. 10045
Federal Deposit Insurance Corporation	550 17th Street, N.W. Washington, D.C. 20429
The Clearing House Association L.L.C.	New York, New York 10005

(b) Whether it is authorized to exercise corporate trust powers.

Yes.

2. Affiliations with Obligor and any Guarantor.

If the obligor or any guarantor is an affiliate of the trustee, describe each such affiliation. 

None.

3-15. Pursuant to General Instruction B of the Form T-1, no responses are included for Items 3-15 of this Form T-1 because, to the best of the Trustee’s knowledge, neither the obligor nor any guarantor is in default under any Indenture for which the Trustee acts as Trustee and the Trustee is not a foreign trustee as provided under Item 15 .

16. List of Exhibits.

Exhibits identified in parentheses below, on file with the Commission, are incorporated herein by reference as an exhibit hereto, pursuant to Rule 7a-29 under the Trust Indenture Act of 1939 (the “Act”) and 17 C.F.R. 229.10(d).

1. A copy of the Organization Certificate of The Bank of New York Mellon (formerly known as The Bank of New York, itself formerly Irving Trust Company) as now in effect, which contains the authority to commence business and a grant of powers to exercise corporate trust powers. (Exhibit 1 to Amendment No. 1 to Form T 1 filed with Registration Statement No. 33-6215, Exhibits 1a and 1b to Form T-1 filed with Registration Statement No. 33-21672, Exhibit 1 to Form T-1 filed with Registration Statement No. 33-29637, Exhibit 1 to Form T-1 filed with Registration Statement No. 333-121195 and Exhibit 1 to Form T-1 filed with Registration Statement No. 333-152735).

4. A copy of the existing By-laws of the Trustee. (Exhibit 4 to Form T-1 filed with Registration Statement No. 333-154173).

6. The consent of the Trustee required by Section 321(b) of the Act (Exhibit 6 to Form T-1 filed with Registration Statement No. 333-152735).

7. A copy of the latest report of condition of the Trustee published pursuant to law or to the requirements of its supervising or examining authority.

SIGNATURE

Pursuant to the requirements of the Act, the Trustee, The Bank of New York Mellon, a corporation organized and existing under the laws of the State of New York, has duly caused this statement of eligibility to be signed on its behalf by the undersigned, thereunto duly authorized, all in the Borough of Woodland Park, and State of New Jersey, on April 19, 2024.

THE BANK OF NEW YORK MELLON
By:	/s/ Denise Kellerk
	Name: Denise Kellerk
	Title: Vice President

 Exhibit 7

Consolidated Report of Condition of

THE BANK OF NEW YORK MELLON

of 240 Greenwich Street, New York, N.Y. 10286
And Foreign and Domestic Subsidiaries, 

a member of the Federal Reserve System, at the close of business December 31, 2023, published in accordance with a call made by the Federal Reserve Bank of this District pursuant to the provisions of the Federal Reserve Act.

	Dollar amounts in thousands
ASSETS
Cash and balances due from depository institutions:
Noninterest-bearing balances and currency and coin		4,078,000
Interest-bearing balances		119,816,000
Securities:
Held-to-maturity securities		49,578,000
Available-for-sale debt securities		76,492,000
Equity securities with readily determinable fair values not held for trading		0
Federal funds sold and securities purchased under agreements to resell:
Federal funds sold in domestic offices		0
Securities purchased under agreements to resell		13,524,000
Loans and lease financing receivables:
Loans and leases held for sale		0
Loans and leases held for investment		32,622,000
LESS: Allowance for loan and lease losses		285,000
Loans and leases held for investment, net of allowance		32,337,000
Trading assets		5,476,000
Premises and fixed assets (including capitalized leases)		2,754,000
Other real estate owned		2,000
Investments in unconsolidated subsidiaries and associated companies		1,560,000
Direct and indirect investments in real estate ventures		0
Intangible assets		6,934,000
Other assets		19,978,000
Total assets		332,529,000
LIABILITIES
Deposits:
In domestic offices		188,830,000
Noninterest-bearing		58,891,000
Interest-bearing		129,939,000
In foreign offices, Edge and Agreement subsidiaries, and IBFs		98,296,000
Noninterest-bearing		3,925,000
Interest-bearing		94,371,000
Federal funds purchased and securities sold under agreements to repurchase:
Federal funds purchased in domestic offices		0
Securities sold under agreements to repurchase		3,820,000
Trading liabilities		3,653,000
Other borrowed money: (includes mortgage indebtedness and obligations under capitalized leases)		1,700,000
Not applicable
Not applicable
Subordinated notes and debentures		0
Other liabilities		8,604,000
Total liabilities		304,903,000
EQUITY CAPITAL
Perpetual preferred stock and related surplus		0
Common stock		1,135,000
Surplus (exclude all surplus related to preferred stock)		12,224,000
Retained earnings		17,672,000
Accumulated other comprehensive income		-3,405,000
Other equity capital components		0
Total bank equity capital		27,626,000
Noncontrolling (minority) interests in consolidated subsidiaries		0
Total equity capital		27,626,000
Total liabilities and equity capital		332,529,000

I, Dermot McDonogh, Chief Financial Officer of the above-named bank do hereby declare that this Report of Condition is true and correct to the best of my knowledge and belief.

Dermot McDonogh
Chief Financial Officer

We, the undersigned directors, attest to the correctness of this statement of resources and liabilities. We declare that it has been examined by us, and to the best of our knowledge and belief has been prepared in conformance with the instructions and is true and correct.

Robin A. Vince
Jeffrey A. Goldstein
Joseph J. Echevarria Directors