Adjunct Superintendent Resolution No. 018-2025-SMV/11

PERU Ministry of Economy and Finance

SMV
Securities Market Superintendence
Electronically signed document within the framework of Law No. 27269, Law on Digital Signatures and Certificates, its Regulations and amendments. The integrity of the document and authorship Adjunct Superintendent Resolution SMV No. 018-2025-SMV/11 Lima, March 5, 2025 Summary: To sanction EXPERTIA TRAVEL S.A. with two (02) warnings for having committed two (02) minor infractions typified in subsection 3.1 of numeral 3 of Annex I of the Sanctions Regulation. Administrated Entity: EXPERTIA TRAVEL S.A. Subject: Administrative Sanctioning Procedure of single administrative instance Main Type: Subsection 3.1 of numeral 3 of Annex I of the Sanctions Regulation MINOR INFRACTIONS File No.: 2025001642 The Adjunct Superintendent of Market Conduct Supervision SEEN:
The administrative file No. 2025001642, containing the administrative sanctioning procedure initiated by the General Superintendent of Conduct Compliance of the Securities Market Superintendence – SMV (hereinafter, the IGCC), against Expertia Travel S.A. (hereinafter, the Issuer); as well as Report No. 235-2025-SMV/11.2 (hereinafter, the Report), issued by the IGCC; CONSIDERING:
I. FUNCTION AND COMPETENCE OF THE SASCM

1. That the IGCC – the instructing body of the administrative sanctioning procedures (hereinafter, the PAS) referred to in this case – has brought to the knowledge of the Adjunct Superintendence of Market Conduct Supervision of the SMV (hereinafter, SASCM), the PAS of administrative file No. 2025001642, with the aim that it issues a decision as the sanctioning body of first or single administrative instance, as appropriate for the type of infractions evaluated in said PAS. In this way, the SASCM assumes competence in observance of the exercise of the supervision function

PERU Ministry of Economy and Finance

SMV
Securities Market Superintendence
Electronically signed document within the framework of Law No. 27269, Law on Digital Signatures and Certificates, its Regulations and amendments. The integrity of the document and authorship and of the sanctioning faculty of the Securities Market Superintendence – SMV established through the Unified Concorded Text of its Organic Law, Law Decree No. 26126 (hereinafter, LOSMV), and the Unified Ordained Text of the Securities Market Law, Legislative Decree No. 861, approved by Supreme Decree No. 020-2023-EF-1 (hereinafter, TUO LMV); as well as by what is provided in the Sanctions Regulation, approved by SMV Resolution No. 035-2018-SMV/01 (hereinafter, Sanctions Regulation); and, in articles 42 and 43 of the Organization and Functions Regulation of the Securities Market Superintendence – SMV, approved by Supreme Decree No. 216-2011-EF (hereinafter, ROF-SMV), in the sense that it is a specific function of the SASCM to impose sanctions in a single administrative instance, the compliance control of which corresponds to the said Adjunct Superintendence. Likewise; the SASCM has the faculties to issue corrective measures aimed at reversing the situation altered by the commission of the infraction;
II. FACTS, CHARGES AND DEFENSES OF THE ISSUER
2.1 Facts
2. That it was evaluated whether the Issuer complied or not with disclosing to the securities market periodic and eventual information;
2.2 Charges
3. That, as a result of said evaluation, through Letter No. 307-2025-SMV/11.2 (hereinafter, Letter of Charges), the following charges were formulated against the Issuer:
MATERIAL FACTS
To communicate the call to the Shareholders' General Meeting for September 9 and 16, 2024, in first and second call, respectively, agreed upon in the Shareholders' General Meeting held on September 4, 2024, which should have been communicated on the same day; however, it was communicated on September 9, 2024. (File No. 2024038278).
FINANCIAL INFORMATION
To present the Individual Interim Financial Statements as of September 30, 2023, and its respective Management Report, which should have been presented by the deadline of October 31, 2023; however, they were presented on November 1, 2023. (File No. 2023046238);
2.3 Defenses
4. That, through a document presented on January 27, 2025, the Issuer presented its defenses stating the following:
“Expertia expressly acknowledges responsibility for having submitted late the call to the general shareholders meeting held on September 4, 2024, and the interim financial information as of September 30, 2023, and its management report.
(…)

1 Through Supreme Decree No. 020-2023-EF, published on February 10, 2023 in the Official Gazette El Peruano, the Unified Ordained Text of the Securities Market Law, Legislative Decree No. 861, was approved.

PERU Ministry of Economy and Finance

SMV
Securities Market Superintendence
Electronically signed document within the framework of Law No. 27269, Law on Digital Signatures and Certificates, its Regulations and amendments. The integrity of the document and authorship We request that the acknowledgment of the fault by Expertia be taken into consideration, which constitutes a mitigating factor as established in subsection a) of article 26 of the Sanctions Regulation, in conjunction with numeral 2, subsection a, of article 257 of the General Administrative Procedure Law.”;
5. That, through Supreme Decree No. 004-2019-JUS, the Unified Ordained Text of Law No. 27444, General Administrative Procedure Law (hereinafter, TUO of the LPAG), was approved, which contains common norms for the actions of the administrative function of the State and regulates all administrative procedures developed in the entities, including special procedures. Likewise, numeral 3) of article 248 of the TUO of the LPAG, indicates the criteria regarding the graduation of the sanction: (a) The illicit benefit resulting from the commission of the infraction, (b) The probability of detection of the infraction, (c) The gravity of the damage to the public interest and/or protected legal good, (d) The economic harm caused, (e) Recidivism, for the commission of the same infraction within a period of one (1) year from when the resolution sanctioning the first infraction became final, (f) The circumstances of the commission of the infraction and, (g) The existence or not of intent in the conduct of the offender;
6. That, the charges, the defenses, and the criteria regarding the graduation of the sanction have been the subject of evaluation in the Report, which has been submitted to the knowledge of the SASCM;
7. That, in observance of what is provided by numeral 5 of article 255 of the TUO of the LPAG, through Letter No. 1005-2025-SMV/11 of February 20, 2025, the Report was sent to the Issuer so that it could formulate its allegations within a period of five (05) business days; however, despite being legally notified via the MVNet System in accordance with the MVNet Regulation, to date, it has not presented them;
III. MATTERS TO BE DETERMINED
8. That, in the present PAS it corresponds to determine the following:
(i) Whether the Issuer incurred or not in the infractions indicated in the Letter of Charges and Report; (ii) Whether it corresponds or not to impose a sanction on the Issuer;
IV. ANALYSIS
4.1 Applicable Normativity
Material Facts
9. That, article 30 of the TUO of the LMV states: “The registration of a certain value or issuance program entails for its issuer the obligation to inform the SMV and, if applicable, to the respective stock exchange or entity responsible for the conduct of the centralized trading mechanism, of material facts, including ongoing negotiations, about itself, the value, and the offer made of it, as well as to disclose such facts in a truthful, sufficient, and timely manner. The information must be provided to said institutions and disclosed as soon as the fact occurs or the issuer takes knowledge of it, as the case may be.” (Underline added);
10. That, numeral 9.1 of article 9 of the Regulation on Material Facts and Reserved Information, approved by SMV Resolution No. 005-2014-SMV/01 (hereinafter, Regulation on Material Facts), states:

PERU Ministry of Economy and Finance

SMV
Securities Market Superintendence
Electronically signed document within the framework of Law No. 27269, Law on Digital Signatures and Certificates, its Regulations and amendments. The integrity of the document and authorship “The Issuer must inform its material fact as soon as such fact occurs or the Issuer takes knowledge of it, and in no case beyond the day on which it has occurred or has been known (…)”. (Underline added);
11. That, numeral 5.1 of article 5 of the Regulation on Material Facts states that: “In the Annex that forms part of this Regulation, an enumerative list of facts, acts, agreements, and decisions is included, which aims to facilitate the Issuer in the identification, qualification, and classification of the information that could qualify as a material fact”;
12. That, regarding this matter, numeral 1 of Annex 1 of the Regulation on Material Facts, provides the following:
“1. Call to shareholders' meetings, creditors' meetings, or bondholders' assemblies, indicating the respective agenda and the documentation that is available to shareholders, creditors, and bondholders, as the case may be, as well as the agreements adopted in them. (…)”. (Underline added); Financial Information
13. That, article 31 of the TUO of the LMV establishes:
“What is provided in the previous article does not relieve the issuer of the timely delivery to the SMV and, if applicable, to the respective stock exchange or entity responsible for the conduct of the centralized trading mechanism, of the information that one or the other requires from it, and necessarily, that indicated below:
a) Its financial statements and indicators, with the minimum information generally indicated by the SMV, with a periodicity not greater than quarterly; and, (…)” (Underline added);
14. That, regarding the deadline for the approval and presentation of Individual Interim Financial Statements for the third quarter (with a closing date of September 30), articles 2, 4, and 5 of the Norms on Preparation and Presentation of Financial Statements, in force at the time the facts occurred, establish that issuers with values registered in the RPMV are obligated to prepare, together with the Management Report, individual and consolidated interim financial statements, and must present said financial information on the day it was approved by the corresponding body, and in no case beyond the day on which this has occurred, being the deadline for its approval and respective presentation October 31 of each year;
15. That, it should be noted that on December 10, 2023, the Norms on Preparation, Presentation, and Dissemination of Financial Statements and Annual Report and Management Report applicable to entities supervised by the SMV, approved by SMV Resolution No. 013-2023-SMV/01, were published in the Official Gazette El Peruano, which are in force from December 11, 2023 (hereinafter, New Norms on Preparation, Presentation, and Dissemination of Financial Statements);
16. That, according to articles 14, 15, and 21 of the new Norms on Preparation, Presentation, and Dissemination of Financial Statements 2 , the

2 Article 14.- Individual or separate interim financial statements Correspond to the statements whose closing dates of the interim period are March 31, June 30, September 30, and December 31 of each year.
In the case of intermediation agents, what is provided in the regulation on the matter shall apply.

PERU Ministry of Economy and Finance

SMV
Securities Market Superintendence
Electronically signed document within the framework of Law No. 27269, Law on Digital Signatures and Certificates, its Regulations and amendments. The integrity of the document and authorship obligations and deadlines regarding the presentation of Individual Interim Financial Statements together with their respective Management Report are maintained, obligations that are evaluated in the present administrative sanctioning procedure;
17. That, in that sense, for the purpose of determining the possible sanction, these infractions are typified as minor infractions in subsection 3.1 of numeral 3 of Annex I of the Sanctions Regulation, which establishes as an infraction: “To present outside the established deadline, or to do so incompletely, or, without observing the technical specifications approved by the SMV or without communicating the approval by the corresponding corporate body, to the SMV, to the Stock Exchange, to the entity in charge of the centralized trading mechanism, or to any other entity or subject of the securities market, the individual or consolidated audited financial information, the individual or consolidated interim financial statements, management report, special audit report, material facts, and annual reports”. (Highlight added);
18. That, according to article 35 of the Sanctions Regulation, said infractions are sanctionable with a warning or a fine not less than one (01) UIT and up to twenty-five (25) UIT;
4.2 Evaluation of the case
19. That, in the administrative file No. 2025001642, which contains the documentation of the present PAS, it is appreciated that through Memorandum No. 331-2024-SMV/11.1 of January 19, 2024 (File No. 2024002372) and Memorandum No. 5403-2024-SMV/11.1 of December 30, 2024 (File No. 2024051999), the General Superintendent of Conduct Supervision (hereinafter, IGSC) – an organ of the Securities Market Superintendence – SMV that has within its functions and faculties, the supervision of compliance with the norms applicable to issuer companies with values registered in the RPMV, evaluating the indications of possible infractions, and remits, for its consideration, the respective reports of indications of infractions, to the IGCC – remitted to the IGCC, the result of its evaluation, and specifically what refers to the present PAS;
20. That, it must be kept in mind that the procedures and legal forms with which the IGSC conducts its audit and/or supervision activity and upon concluding it with a report of indications of infractions, determine that its pronouncement or opinion on a specific topic of supervision – which can even contain a decision, such as, for example, the adoption of corrective measures – is an opinion on the merits of the matter;
being specified that said opinion and the report of indications of infractions of the IGSC is not binding for the IGCC, as established in the second paragraph of article 9 of the Sanctions Regulation 3 4 ;
21. That, in this way, it is had that in the evaluation of the facts related to the present PAS, two (2) other organs or administrative instances of the SMV, functionally independent from each other and from this Office, have intervened and participated previously to the issuance of this resolution; first the IGSC which at its opportunity reported the indications of infractions and then the IGCC which, as a result of its evaluation, formulated the Letter of Charges and the Report; and at this point of the PAS it corresponds to the Office of the SASCM to issue a pronouncement containing its decision regarding the mentioned charges, being precise to indicate that by the nature of the same, as has been previously indicated, it will be a decision of single administrative instance;
22. That, as previously mentioned, through a document of January 27, 2025, the Issuer presented its defenses regarding the imputations formulated against it in the present file;
23. That, regarding this, the Issuer has expressly and unconditionally acknowledged its responsibility for the entirety of the imputed infractions and requested the reduction of the fine by fifty percent (50%), by virtue of what is provided in numeral 1 of subsection a) of article 26 of the Sanctions Regulation;
24. That, regarding this, having the Issuer presented its defenses within the period granted for the presentation of defenses, it corresponds to indicate that the voluntary declaration of acknowledgment of the infraction by the Issuer is reputed as a condition of mitigating responsibility, so that when the applicable sanction is a fine, it is reduced by fifty percent (50%) if the acknowledgment is presented within the period granted to present defenses, according to numeral 1 of subsection a) of article 26 of the Sanctions Regulation, concordant with subsection a) of numeral 2 of article 257

3 In article 245 of the TUO of the LPAG, the forms or modes in which the audit activity could be concluded are indicated as follows: 1) Certificate of conformity of the activity developed by the administrated entity; 2) Recommendation of improvements or corrections of the activity developed by the administrated entity; 3) The warning of the existence of non-compliances not susceptible of meriting the determination of administrative responsibilities; 4) The recommendation of the initiation of a procedure with the aim of determining the administrative responsibilities that correspond; 5) The adoption of corrective measures and 6) Other forms as established by special laws. 4 «Article 9.- Preliminary inquiries as a consequence of supervision actions (…) When said organs conclude that there are sufficient indications of possible administrative infractions, they remit the corresponding reports to the General Superintendencies of Compliance, which determine if it corresponds to initiate or not an administrative sanctioning procedure. If the case arises, the General Superintendencies of Compliance may carry out additional inspections or investigations of the reported indications. In the case of possible infractions in the scope of the Regulation on the Participatory Financial Financing Activity and its Managing Societies, the preliminary inquiries are carried out by the General Superintendent of Investigation and Innovation, a dependency that, if there are sufficient indications of possible administrative infractions, will determine if it corresponds to initiate or not an administrative sanctioning procedure. (…)».

PERU Ministry of Economy and Finance

SMV
Superintendencia del Mercado de Valores
Document electronically signed digitally under Law No. 27269, Law of Digital Signatures and Certificates, its regulations and amendments. The integrity of the document and the authorship of the TUO of the LPAG, which will be considered at the time of determining the sanction;

25. That, consequently, the conduct constitutive of the two (02) infractions subject to charges is accredited and the administrative responsibility of the Issuer is determined; therefore, it is necessary to analyze the sanction proposal in accordance with the principle of reasonableness, the defenses, and the sanctioning criteria, which will be evaluated in the section on determination of the sanction;

V. DETERMINATION OF THE SANCTION

26. That, for the purpose of determining possible sanctions, it should be noted that infractions regarding the late communication of material events as well as the late submission of financial information are considered minor infractions according to paragraph 3.1 of numeral 3 of Annex I of the Sanctions Regulation, which states that it constitutes a minor infraction:

"To submit outside the established deadline, or to do so incompletely, or without observing the technical specifications approved by the SMV or without communicating the approval by the corresponding corporate body to the SMV, to the Stock Exchange, to the entity in charge of the centralized negotiation mechanism or to any other entity or subject of the securities market, the individual or consolidated audited financial information, the individual or consolidated interim financial statements, management report, special audit report, material events, and annual reports." (Highlight added);

27. That, according to Article 35 of the Sanctions Regulation, these infractions must be sanctioned with a warning or a fine not less than one (1) UIT and up to the limit of twenty-five (25) UIT;

5.1 Sanctioning Criteria

28. That, having determined the commission of the imputed infractions, it is necessary to evaluate the sanction in accordance with Article 25 of the Sanctions Regulation, consistent with numeral 3) of Article 248 of the TUO of the LPAG and Article 344 of the TUO of the LMV, which develop the criteria for sanction graduation: (i) the issuer's sanction record, (ii) recidivism, (iii) the circumstances of the commission of the infraction, (iv) the economic damage caused and its repercussion on the market, (v) the illicit benefit resulting from the commission of the infraction, (vi) the probability of detection of the infraction, (vii) the gravity of the damage to the public interest and/or protected legal good, and (viii) the existence or non-existence of intent in the infringer's conduct;

29. That, in addition to the previously cited norms, for the purpose of determining the sanction to be imposed on the Issuer for the non-compliance regarding the late submission of financial information, the Criteria applicable to the administrative sanctioning procedure for non-compliance with the norms regulating the transmission of periodic or eventual information, approved by SMV Resolution No. 006-2012-SMV/01, valid at the time of the commission of the infractions (hereinafter, Special Sanctioning Criteria), must be taken into account;

30. That, likewise, regarding the non-compliance subject to charges referred to the late communication of material events, it should be indicated that through Article 1 of SMV Resolution No. 007-2023-SMV/01 of September 4, 2023, the Gradual Sanction Regime for late submission of financial information, annual report, and material events (hereinafter, New Gradual Sanction Regime) was approved, whose Article 4 established its validity from January 1, 2024; and in Article 2 of the aforementioned Resolution, the Special Sanctioning Criteria are repealed;

31. That, in view of the foregoing and considering that the regulation has been modified during the processing of the present PAS, it is necessary to analyze whether in the present case the provisions of the New Gradual Sanction Regime should be applied by virtue of the Principle of Favorable Retroactivity, established in numeral 5 of Article 248 of the TUO of the LPAG, which states that: "(...) sanctioning provisions in force at the time the administrator incurs the conduct to be sanctioned are applicable, unless subsequent ones are more favorable to him";

32. That, in application of the aforementioned norms, the following is evaluated:

33. That, with respect to the gravity of the damage to the public interest and/or protected legal good, it should be indicated that the timely submission of periodic or eventual information by issuers of securities registered in the RPMV constitutes a fundamental obligation in the transparency of the securities market, so that market participants can make their investment decisions adequately informed. Consequently, although no gravity of damage to the public interest is evidenced, the non-compliance with the obligation to inform the market within the deadline limits by the issuers affects market transparency, which is considered a protected legal good;

34. That, regarding the sanction record, letter a) of Article 25 of the Sanctions Regulation establishes that they are the final sanctions imposed by the Superintendencia del Mercado de Valores – SMV within the four (4) years prior to the commission of the infraction to be sanctioned; notwithstanding this, it is clarified that the commission of the same infraction in the year prior to the infraction to be sanctioned is not considered as a record. On this matter, from the verification carried out in the SMV Sanctions System, it has been determined that the Issuer has one (01) sanction record, as detailed in the Report;

35. That, regarding recidivism for the commission of the same infraction, it is appropriate to note that the Sanctioning Criteria, valid at the time of the commission of these facts, did not include recidivism as a criterion to be taken into account for the application of the sanction; this criterion was only incorporated in the New Gradual Sanction Regime, which establishes in numeral 5.2 that "Recidivism is considered to exist if, during the year prior to the commission of the infraction to be sanctioned, the person has been sanctioned for an infraction of the same nature as the one intended to be sanctioned, provided that such sanction has become final during said period", likewise, the New Gradual Sanction Regime states that for the purpose of determining recidivism as an aggravating factor, a quantum of up to 10% has been established that would be added to the fine proposal, if it is verified that the infringer is a recidivist. Regarding this, it has been verified that there is no recidivism on the part of the Issuer;

36. That, regarding the circumstances of the commission of the infraction, it should be noted that, from the verification of the information disseminated by the issuers on the SMV Institutional Page, the following is observed:

PERÚ Ministry of Economy and Finance

SMV
Superintendencia del Mercado de Valores
Document electronically signed digitally under Law No. 27269, Law of Digital Signatures and Certificates, its regulations and amendments. The integrity of the document and the authorship

• The late communication of the material event referred to the call to the Shareholders' General Meeting agreed on September 4, 2024, which should have been communicated on the same day; however, it was communicated on September 9, 2024. (with five (05) calendar days of delay).
• The late submission of the Individual Interim Financial Statements as of September 30, 2023 and its respective Management Report, which should have been submitted by the latest deadline of October 31, 2023; however, they were submitted on November 1, 2023 (with one (01) calendar day of delay);

37. That, with regard to the economic damage caused and its repercussion on the market, this criterion evaluates quantifiable or non-quantifiable damage produced by the administrative infraction, which includes the evaluation of economic damages caused. In this sense, it has not been evidenced that the non-compliances produced a quantifiable damage, understood as an economic damage caused to one or more investors;

38. That, regarding the illicit benefit resulting from the commission of the infraction, it should be noted that there are not sufficient elements to indicate that the Issuer, as a consequence of the infractions committed, has obtained or generated an illicit benefit;

39. That, with regard to the probability of detection of the infraction, it should be noted that the failure to timely submit periodic or eventual information is verified through internal control systems, so it is considered that for this type of non-compliance, the probability of detection is high;

40. That, regarding the existence or non-existence of intent in the infringer's conduct, it can be noted that there are not sufficient elements to indicate that the Issuer acted with intent in the commission of the infractions, so this criterion would not have been configured. However, it is necessary to indicate that despite there being no indications to suggest that the Issuer acted with intent, it can be affirmed that the Issuer's conduct was negligent, as it did not act with the diligence required given obligations already known by the Issuer;

Evaluation of the Principle of Favorable Retroactivity

41. That, in the present case, although the Issuer has a sanction record, it is not observed that it has incurred in the aggravating circumstances referred to recidivism, accreditation of quantifiable damage, a serious repercussion on the market, having obtained an illegal benefit or intent in the commission of the infraction; therefore, the sanction to be imposed would be a warning for each non-compliance;

42. That, it should be noted that it has been verified that the infractions subject to charges simultaneously meet the conditions established in paragraph ii) of numeral 4.2 of the Old Sanctioning Criteria, valid at the time of the commission of the infractions, as well as those indicated in numeral 6.1 of the New Gradual Sanction Regime; therefore, there is no more favorable norm, since in both cases it corresponds to apply as a sanction a warning for each non-compliance;

On the Application of the Warning Sanction

PERÚ Ministry of Economy and Finance

SMV
Superintendencia del Mercado de Valores
Document electronically signed digitally under Law No. 27269, Law of Digital Signatures and Certificates, its regulations and amendments. The integrity of the document and the authorship

43. That, paragraph ii) of numeral 4.2 of the Old Sanctioning Criteria states that the warning sanction may be applied when the following occur simultaneously: (i) The impact on market transparency is minimal; (ii) The infraction committed has not caused concrete damage to investors or associates; (iii) The infringing subject does not have records or, having them, they are infractions classified as minor offenses imposed in the four (4) years prior to the commission of the infraction being evaluated; (iv) The infringing subject has not obtained a benefit from its illegal conduct; and, (v) It has not been proven that the infringer acted with intent in the commission of the infraction;

44. That, as detailed in the evaluation of the Sanctioning Criteria, it can be noted that: (i) The impact on market transparency was minimal; (ii) The infractions committed have not caused concrete damage to investors or associates, since no type of complaint or receipt of indication regarding this has been registered; (iii) The Issuer has records of infractions classified as minor infractions; (iv) The infringing subject has not obtained a benefit from its illegal conduct; and, (v) It has not been proven that the infringer acted with intent in the commission of the infraction;

45. That, therefore, having concurrently fulfilled what is stated in paragraph ii) of numeral 4.2 of the Old Sanctioning Criteria, valid at the time of the commission of the infractions, as well as those indicated in numeral 6.1 of the New Gradual Sanction Regime, it corresponds to impose on the Issuer two (02) warnings for the non-compliances subject to charges;

On the Recognition of Responsibility

46. That, the Issuer through a defense letter dated January 27, 2025, expressly recognized responsibility for the charges of the present procedure. However, the mitigating circumstance of responsibility by recognition of responsibility of the infringer regarding the non-compliances is not applicable, according to numeral 1 of letter a) of Article 26 of the Sanctions Regulation, insofar as the sanction proposal for these infractions is a warning, and;

Being in accordance with what is established in numerals 14 and 36 of Article 43 of the Regulation of Organization and Functions of the Superintendencia del Mercado de Valores – SMV, approved by Supreme Decree No. 216-2011-EF;

RESOLVES:

Article 1º.- Declare that Expertia Travel S.A. has incurred two (02) minor infractions typified in numeral 3, paragraph 3.1 of Annex I of the Sanctions Regulation, approved by SMV Resolution No. 035-2018-SMV/01 for: (i) communicating late the call to the Shareholders' General Meeting for September 9 and 16, 2024 in first and second call, respectively, agreed in the Shareholders' General Meeting held on September 4, 2024, which should have been communicated on the same day; however, it was communicated on September 9, 2024; and (ii) submitting late the Individual Interim Financial Statements as of September 30, 2023 and its respective Management Report, which should have been submitted by the latest deadline of October 31, 2023.

Article 2º.- Sanction Expertia Travel S.A. with two (02) warnings for what is established in Article 1 of this Resolution.

PERÚ Ministry of Economy and Finance

SMV
Superintendencia del Mercado de Valores
Document electronically signed digitally under Law No. 27269, Law of Digital Signatures and Certificates, its regulations and amendments. The integrity of the document and the authorship

Article 3º.- This Resolution does not exhaust the administrative route, it may be challenged before this Superintendents Adjunct of Market Conduct Supervision by filing the reconsideration appeal, administrative appeal recognized in Article 218 of the Single Text of the General Administrative Procedure Law No. 27444, approved by Supreme Decree No. 004-2019-JUS, within the term of fifteen (15) business days counted from the day following its notification, as it is a procedure of a single administrative instance.

Article 4º.- In case this Resolution is not subject to challenge, it must be published on the "SMV Institutional Page on the Unique Digital Platform of the Peruvian State for Citizen Orientation (www.gob.pe/smv)", in observance of what is established in numeral 1 of Article 7 of the "Policy on dissemination of normative projects, general legal norms, early agenda and other administrative acts of the SMV", approved by SMV Resolution No. 014-2014-SMV/01, and by what is established in the last paragraph of Article 14 of the Sanctions Regulation, approved by SMV Resolution No. 035-2018-SMV/01.

Article 5º.- Transcribe this Resolution to Expertia Travel S.A.

Register, communicate and publish.

Carlos Rivero Zevallos
Superintendente Adjunto
Superintendencia Adjunta de Supervisión de Conductas de Mercados