Adjunct Superintendent Resolution No. 025-2026-SMV/11

PERÚ Ministry of Economy and Finance

SMV Securities Market Superintendency "Decade of Equal Opportunities for Women and Men" "Year of Hope and Strengthening of Democracy" 1 Electronically signed document in the framework of Law No. 27269, Law of Digital Signatures and Certificates, its regulations and amendments. The integrity of the document and the authorship of the signature(s) can be verified at https://apps.firmaperu.gob.pe/web/validador.xhtml Adjunct Superintendent Resolution SMV No. 025-2026-SMV/11 Lima, June 25, 2026

Summary: To sanction CAJA MUNICIPAL DE AHORRO AND CREDIT CUSCO S.A. with one (01) censure for having committed one (01) minor infraction typified in subsection 3.1 of numeral 3 of Annex I of the Sanctions Regulation. Administered Entity: CAJA MUNICIPAL DE AHORRO Y CRÉDITO CUSCO 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.: 2026005577 The Adjunct Superintendent of Supervision of Market Conduct SEEN: The administrative file No. 2026005577, containing the administrative sanctioning procedure initiated by the General Intendancy of Conduct Compliance of the Securities Market Superintendency – SMV (hereinafter, the IGCC), against CAJA MUNICIPAL DE AHORRO Y CRÉDITO CUSCO S.A. (hereinafter, the Issuer); as well as Report No. 843-2026-SMV/11.2 (hereinafter, the Report), issued by the IGCC; CONSIDERING: I. FUNCTION AND COMPETENCE OF THE SASCM

1. That, the IGCC —instructor body of the administrative sanctioning procedures (hereinafter, the PAS) referred to in the present case—, has brought to the knowledge of the Adjunct Superintendency of Supervision of Market Conduct of the SMV (hereinafter, SASCM), the PAS of the administrative file No. 2026005577, in order that it issues a decision as the sanctioning body of single administrative instance. In this way, the SASCM assumes competence in observance of the exercise of the supervision function and of the sanctioning faculty of the Securities Market Superintendency – SMV established through the Unified Concordant Text of its Organic Law, Decree Law No. 26126 (hereinafter, LOSMV), and the Unified Ordered Text of the Securities Market Law, Legislative Decree No. 861, approved by Supreme Decree No. 020-2023-EF-1 1 (hereinafter, TUO of the 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 Regulations on Organization and Functions of the Securities Market Superintendency – SMV, approved by Supreme Decree No. 216-2011-EF (hereinafter, ROF-SMV), in the sense that it is a specific function of the SASCM, imposing sanctions in single administrative instance for the commission of infractions whose compliance control corresponds to the said Adjunct Superintendency; II. FACTS, CHARGES AND DEFENSES OF THE ISSUER 2.1 Facts
2. That, it was evaluated whether the Issuer complied or not with disclosing timely to the securities market its periodic or eventual information; 2.2 Charge
3. That, as a result of said evaluation, through Letter No. 814-2026-SMV/11.2 of March 09, 2026 (hereinafter, Letter of Charge), a charge was formulated to the Issuer for presenting belatedly the fact of importance referred to that "on April 15, 2025 a subordinate loan was concluded with Corporación Financiera de Desarrollo S.A. - COFIDE for S/ 50,000,000.00, for a term of 10 years, within the framework of the authorization granted by the Superintendency of Banking, Insurance and AFP – SBS through SBS Resolution No. 01353-2025", which should have been communicated on April 15, 2025 itself; nevertheless, it was communicated on May 08
4. (File No. 2025021276); 2.3 Defenses
5. That, through writing presented on March 23, 2026, the Issuer presented its defenses stating; among others, the following: (i) It expressly manifests that it recognizes its administrative responsibility regarding the non-compliance attributed to it, specifying that such recognition does not constitute a defense writing but an express acceptance of the observed non-compliance. (ii) It indicated that "with regard to the circumstances of the commission of the infraction, it is necessary to specify that CMAC Cusco S.A. had no intention whatsoever to hide the information related to the loan. Indeed, on April 4, 2025,

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

PERÚ Ministry of Economy and Finance

SMV Securities Market Superintendency "Decade of Equal Opportunities for Women and Men" "Year of Hope and Strengthening of Democracy" 2 Electronically signed document in the framework of Law No. 27269, Law of Digital Signatures and Certificates, its regulations and amendments. The integrity of the document and the authorship of the signature(s) can be verified at https://apps.firmaperu.gob.pe/web/validador.xhtml communicated the approval granted by SBS for the contracting of the subordinate loan with COFIDE. Likewise, it complied with carrying out the communication of the Important Fact referred to the conclusion of said loan, without prior request from the authority, which evidences that there was no conduct directed at hiding information, but rather, in any case, an involuntary lag in the timeliness of its presentation." (iii) Likewise, it pointed out that it has no record of sanctions, there is no recidivism, that it had no intention to hide information from the market, did not obtain any illicit benefit, that the subordinate loan strengthens the effective equity of the entity and that no economic damage occurred to investors nor impact on the market. Finally, it requested that taking into account the criteria of graduality, the eventual sanction be determined as a censure; 5. That, the Unified Ordered Text of Law No. 27444, General Administrative Procedure Law, approved by Supreme Decree No. 006- 2026-JUS (hereinafter, TUO of the LPAG contains common rules 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 230 of the TUO of the LPAG, states 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 severity of the damage to the public interest and/or protected legal good, (d) The economic damage 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 235 of the TUO of the LPAG, through Letter No. 2713-2026-SMV/11, it was sent to the Issuer the Report, so that it may send its allegations within the term of five (05) business days of notification; the same have been presented and will be evaluated in this Resolution; 8. That, through writing of June 15, 2026, the Issuer stated as allegations that it leaves on record that with this writing it does not contain defense allegations nor challenges with respect to the facts subject of the present PAS, constituting only a repetition of the express recognition of responsibility previously formulated by the Issuer; III. QUESTIONS TO DETERMINE 9. That, in the present PAS it corresponds to determine the following: (i) Whether the Issuer incurred or not in the infraction indicated in the Letter of Charge and Report; (ii) Whether it corresponds or not to impose a sanction on the Issuer; IV. ANALYSIS

PERÚ Ministry of Economy and Finance

SMV Securities Market Superintendency "Decade of Equal Opportunities for Women and Men" "Year of Hope and Strengthening of Democracy" 4 Electronically signed document in the framework of Law No. 27269, Law of Digital Signatures and Certificates, its regulations and amendments. The integrity of the document and the authorship of the signature(s) can be verified at https://apps.firmaperu.gob.pe/web/validador.xhtml 4.1 Applicable Normativity 10. That, article 30 of the TUO of the LMV, states the following: "Article 30.- Important Facts 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 conducting the centralized trading mechanism, of the important facts, including negotiations in progress, about itself, the value and the offer that is made of it, as well as to disseminate such facts in a truthful, sufficient and timely manner. The information must be provided to these institutions and disseminated as soon as the fact occurs or the issuer takes knowledge of it, as the case may be". (Underlining added); 11. That, numeral 9.1 of article 9 of the Regulation on Important Facts and Confidential Information, approved by SMV Resolution No. 005-2014-SMV/01 (hereinafter, Regulation on Important Facts), which states that "The Issuer must inform its important fact as soon as such fact occurs or the Issuer takes knowledge of it, and in no case beyond the day on which this has occurred or has been known (…)"; 12. That, it is appropriate to indicate that numeral 5.1 of article 5 of the Regulation on Important Facts states the following: "5.1. In the Annex that forms part of this Regulation, a list is included of facts, acts, agreements and decisions, which has the purpose of facilitating for the Issuer the identification, qualification and classification of the information that could qualify as an important fact (...) Any reference to Annex in this article shall be understood as referring to Annex 1."; 13. That, in numeral 16 of Annex 1 that forms part of the Regulation on Important Facts, it is stated that it constitutes an important fact: "16. Acquisition, alienation or restructuring of assets and/or liabilities by amounts significant, as well as relevant encumbrances on assets and capitalization of claims. Likewise, reduction of net equity in an amount equal to or greater than 10%." (Underlining added); 14. That, in the present PAS an infraction would have been incurred which is typified in section 3.1 numeral 3 of Annex I of the Sanctions Regulation, which states that it constitutes a minor infraction: "Present outside the established deadline, or 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 intermediate financial statements, management report, special audit report, important facts and, annual reports." (Underlining added); 15. That, according to article 35 of the Sanctions Regulation, minor infractions are punishable with censure or fine not less than one (1) UIT and up to twenty-five (25) UIT;

PERÚ Ministry of Economy and Finance

SMV Securities Market Superintendency "Decade of Equal Opportunities for Women and Men" "Year of Hope and Strengthening of Democracy" 5 Electronically signed document in the framework of Law No. 27269, Law of Digital Signatures and Certificates, its regulations and amendments. The integrity of the document and the authorship of the signature(s) can be verified at https://apps.firmaperu.gob.pe/web/validador.xhtml 4.2 Evaluation of the case 16. That, in the administrative file No. 2026005577, which contains the documentation of the present PAS, it is appreciated that through Memorandum No. 4493-2025-SMV/11.1 of October 24, 2025 (File No. 2025046294), the General Intendancy of Conduct Supervision (hereinafter, IGSC) —body of the Securities Market Superintendency – SMV that has within its functions and faculties, the supervision of compliance with the norms applicable to issuing companies with values registered in the Public Register of the Securities Market - RPMV, evaluating the indications of possible infractions, and sends, for their consideration, the respective indication reports of infractions, to the IGCC—, the result of its evaluation, and specifically what refers to the present case; 17. That, it must be kept in mind that the procedures and legal forms with which the IGSC conducts its activity of inspection and/or supervision and upon concluding it with an indication report of infraction, determine that its pronouncement or opinion on a specific topic of supervision2 —which even can contain a decision, such as the adoption of corrective measures—, be an opinion on the substance of the matter; it being precise that said opinion and the indication report of infraction of the IGSC is not binding for the IGCC, as established in the second paragraph of article 9 of the Sanctions Regulation3 ; 18. That, in this way it is had that in the evaluation of the facts related to the present PAS have intervened and participated previously to the issuance of the present resolution, two (2) other organs or administrative instances of the SMV, functionally independent from each other and from this Office; first the IGSC that at its opportunity reported the indications of infraction and then the IGCC that, 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, issue a pronouncement containing its decision with respect to the mentioned charges, it being precise to indicate that by the nature of the same, as has been indicated previously, it will be a decision of single administrative instance for the charge attributed; 19. That, as mentioned previously, through writing of March 21, 2026, the Issuer presented its defenses with respect to the charges formulated against it, so that next we proceed to evaluate them: (i) From the review of the file it is evident that the Issuer concluded on April 15 of 2025 a subordinate loan with the Corporación Financiera de Desarrollo S.A. – COFIDE for the sum of S/ 50,000,000.00 and for a term of ten (10) years.

2 In article 228-G of the TUO of the LPAG it is stated as forms or modes in which the inspection activity could conclude the following: 1) Record of conformity of the activity developed by the administered entity; 2) Recommendation of improvements or corrections of the activity developed by the administered 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 in order to determine the administrative responsibilities that correspond; 5) The adoption of corrective measures and 6) Other forms as established by special laws. 3 «Article 9.- Preliminary investigations as a consequence of supervision actions (...) When said organs conclude that there are sufficient indications of possible infractions administrative they remit the corresponding reports to the General Intendancies of Compliance,

PERÚ Ministry of Economy and Finance

SMV Securities Market Superintendency "Decade of Equal Opportunities for Women and Men" "Year of Hope and Strengthening of Democracy" 6 Electronically signed document in the framework of Law No. 27269, Law of Digital Signatures and Certificates, its regulations and amendments. The integrity of the document and the authorship of the signature(s) can be verified at https://apps.firmaperu.gob.pe/web/validador.xhtml Likewise, it is verified that said fact was communicated to the market through important fact, only on May 08, 2025. Consequently, it is found proven that the communication was carried out with subsequent to the deadline provided in article 30 of the TUO of the LMV and in numeral 9.1 of article 9 of the Regulation on Important Facts. (ii) With respect to the defenses presented by the Issuer, it corresponds to state that it has expressly recognized the commission of the infraction attributed to it, indicating that the subordinate loan should have been communicated timely and that the delay in the communication was involuntary. Regarding this, it is considered that the recognition made by the Issuer results consistent with the facts verified in the file, finding proven the belated presentation of the important fact subject of the present procedure. Nevertheless, it corresponds to consider as a mitigating circumstance the express recognition of responsibility formulated by the Issuer within the term granted for the presentation of defenses, according to literal a) of article 26 of the Sanctions Regulation. (iii) It is worth noting that, prior to the occurrence of the fact subject of charge, the Issuer communicated through important fact of April 04, 2025 (File No. 2025015512)4 that it had received Resolution SBS No. 01353- 2025, through which it was authorized to contract a subordinate loan with COFIDE up to the sum of S/ 50'000,000.00 and for a term of ten (10) years. In said communication the Issuer informed expressly that: "today the RESOLUTION SBS No. 01353-2025 has been received through which it is authorized to Caja Cusco to contract a subordinate loan with COFIDE up to the sum of S/ 50´000,000.00 (...) for a term of 10 years". Likewise, Resolution SBS No. 01353-2025 stated expressly that it authorized the Issuer to contract said subordinate loan, computable as part of its effective equity of level 2. In that sense, although the effective conclusion of the subordinate loan constituted an autonomous important fact that should have been communicated timely to the market, it is evident that investors already had previously relevant information regarding the operation, including its amount, term, nature and the authorization issued by the SBS for its celebration. Therefore, the belated communication of the disbursement, subject of charges, did not imply a situation of absolute absence of information regarding the operation, but the delay in the communication of the materialization of an operation whose realization had been previously put in knowledge of the market. (iv) For the considerations exposed, although there was a non-compliance of the obligation to communicate timely an important fact, the particularities of the case reveal a reduced impact on the principle of transparency of the market, since the operation and its main characteristics had been previously revealed to the public investor through

4 https://www.smv.gob.pe/ConsultasP8/temp/Resoluci%c3%b3n%20SBS%20N%c2%b0%2001353-2025- SBS.pdf

PERÚ Ministry of Economy and Finance

SMV Superintendencia del Mercado de Valores “Decenio de la Igualdad de Oportunidades para Mujeres y Hombres” “Año de la Esperanza y el Fortalecimiento de la Democracia” 7 Electronically signed document in the framework of Law No. 27269, Law of Digital Signatures and Certificates, its regulations and amendments. The integrity of the document and the authorship of the signature(s) can be verified at https://apps.firmaperu.gob.pe/web/validador.xhtml material fact dated April 4, 2025, communicated in due time by the Issuer. (v) On the other hand, regarding the Issuer's argument concerning the lack of economic harm, absence of illicit benefit, and lack of intent, it is necessary to indicate that these sanctioning criteria will be evaluated in the corresponding section for the determination of the sanction. 20. That, consequently, the administrative responsibility of the Issuer is considered proven for the late submission of the material fact referred to the execution of the subordinate loan with COFIDE; V. DETERMINATION OF THE SANCTION 21. That, for the purpose of determining the possible sanction, the infringement regarding the late communication of material facts, it must be stated that according to what is provided in paragraph 3.1 of numeral 3 of Annex I of the Sanctions Regulation, it states that it constitutes a minor infringement: “Submit outside the established deadline, or do so incompletely, or, without observing the technical specifications approved by the SMV or without communicating the approval by the corporate body corresponding, 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 audited individual or consolidated financial information, the individual or consolidated interim financial statements, management report, special audit report, material facts, and annual reports.” (Highlighting and underlining added); 22. That, according to what is established in article 35 of the Sanctions Regulation, it corresponds that these infringements be sanctioned with a reprimand or a fine not less than one (1) UIT and up to the limit of twenty-five (25) UIT; 5.1 Sanctioning Criteria 23. That, having determined the commission of the imputed infringement, it corresponds to evaluate the sanction in accordance with article 25 of the Sanctions Regulation, concordant with numeral 3) of article 230 of the TUO of the LPAG and article 344 of the TUO of the LMV, which develop the criteria of sanction graduation: (i) the Issuer's sanctioning antecedents, (ii) recidivism, (iii) the circumstances of the commission of the infringement, (iv) the economic harm caused and its repercussion on the market, (v) the illicit benefit resulting from the commission of the infringement, (vi) the probability of detection of the infringement, (vii) the severity of the damage to the public interest and/or protected legal good and (viii) the existence or not of intent in the conduct of the infringer; 24. That, for the purpose of determining the sanction to be imposed on the Issuer for the non-compliance referred to the late communication of material facts, it must be taken into account the Regime of Gradual Sanctions for late submission of financial information, annual report and material facts (hereinafter, Regime of Gradual Sanctions), approved by SMV Resolution No. 007-2023-SMV/01; 25. That, in application of the aforementioned norms, it proceeds to evaluate the following:

PERÚ Ministerio de Economía y Finanzas

SMV Superintendencia del Mercado de Valores “Decenio de la Igualdad de Oportunidades para Mujeres y Hombres” “Año de la Esperanza y el Fortalecimiento de la Democracia” 8 Electronically signed document in the framework of Law No. 27269, Law of Digital Signatures and Certificates, its regulations and amendments. The integrity of the document and the authorship of the signature(s) can be verified at https://apps.firmaperu.gob.pe/web/validador.xhtml 26. That, with respect to the severity of the damage to public interest and/or protected legal good, it must 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 severity of damage to public interest is evident, the non-compliance with the obligation to inform the market within the legal deadlines by the Issuers affects the transparency of the market, which is considered a protected legal good; 27. That, regarding sanctioning antecedents, the letter a) of article 25 of the Sanctions Regulation states that antecedents of the infringer are the final sanctions imposed by the SMV within four (04) years prior to the moment of the commission of the infringement to be sanctioned. Likewise, the commission of the same infringement in the year prior to the infringement to be sanctioned is not considered antecedents. On the other hand, the Regime of Gradual Sanctions states that “The resulting amount from the application of the guidelines contemplated in numeral 6.2 may be increased up to five percent (5%) if it is proven that the infringing subject has sanctioning antecedents”, without making distinction as to whether they correspond to different or the same type of infringement. On this particular matter, from the verification carried out in the SMV Sanctions System, it has been determined that the Issuer does not have sanctioning antecedents, as detailed in the Report; 28. That, regarding recidivism for the commission of the same infringement, the letter b) of article 25 of the Sanctions Regulation states that to determine recidivism for the commission of the same infringement, it is taken into account that final sanction imposed by the SMV within the period of one (01) year prior to the commission of the infringement to be sanctioned. On the other hand, the Regime of Gradual Sanctions establishes in numeral 5.2 that “It is considered that there is recidivism, if during the year prior to the commission of the infringement to be sanctioned, it has been sanctioned for an infringement of the same nature as the one intended to be sanctioned, provided that such sanction has become final during said period”, likewise, 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 proposed fine, if it is verified that the infringer is a recidivist. In this regard, it has been verified that the Issuer is not a recidivist, as detailed in the Report; 29. That, regarding the circumstances of the commission of the infringement, it must be noted that, from the verification of the information disseminated by the Issuer on the Institutional Page of the SMV on the Digital Platform Unique of the Peruvian State for Citizen Orientation4, it is noted that the Issuer concluded on April 15, 2025 a subordinate loan with COFIDE for the amount of S/ 50,000,000.00 (Fifty Million and 00/100 Soles), for a term of ten (10) years, a fact that should have been communicated to the market via material fact on the same day of its occurrence, nevertheless, such communication was made only on May 08 of 2025. Consequently, it is verified that the Issuer incurred a delay of twenty-three (23) calendar days with respect to the legally established deadline for the communication of the material fact. Notwithstanding this, it is relevant to analyze the specific circumstances in which the non-compliance occurred. In this regard, it is noted that prior to the

PERÚ Ministerio de Economía y Finanzas

SMV Superintendencia del Mercado de Valores “Decenio de la Igualdad de Oportunidades para Mujeres y Hombres” “Año de la Esperanza y el Fortalecimiento de la Democracia” 9 Electronically signed document in the framework of Law No. 27269, Law of Digital Signatures and Certificates, its regulations and amendments. The integrity of the document and the authorship of the signature(s) can be verified at https://apps.firmaperu.gob.pe/web/validador.xhtml execution of the subordinate loan, the Issuer timely communicated to the market, via material fact dated April 4, 2025 (File No. 2025015512), that it had received Resolution SBS No. 01353-2025, through which the Superintendency of Banks, Insurance and AFP authorized the entity to contract a subordinate loan with COFIDE up to the amount of S/ 50,000,000.00 and for a term of ten (10) years. On the other hand, from the information published on the Institutional Page of the SMV corresponding to “Related” of the Issuer, it is noted that it has as its sole shareholder the Provincial Municipality of Cusco, which maintains 100% participation in the Issuer's share capital; Image No. 1: Shareholders of the Issuer 30. That, regarding the economic harm caused and its repercussion on the market, we must state that it has not been evidenced that the non-compliance has produced a quantifiable harm, understood as an economic damage caused to one or several investors; 31. That, regarding the illicit benefit resulting from the commission of the infringement, it must be stated that there are not sufficient elements to indicate that the Issuer, as a consequence of the infringements committed, has obtained generated an illicit benefit; 32. That, regarding the probability of detection of the infringement, it must be stated 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; 33. That, regarding the existence or not of intent in the conduct of the infringer, it can be stated that there are not sufficient elements to indicate that the Issuer acted with intent in the commission of the infringement, 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; 5.2 On the application of the reprimand sanction 34. That, regarding the communication of material facts and submission of financial information, numeral 6.1 of the Regime of Gradual Sanctions states that the reprimand sanction may be applied when the following occur simultaneously: (i) When the impact on market transparency is minimal; (ii) The infringement committed has not caused a concrete harm to investors or associates; (iii) The infringing subject does not have antecedents or, having them, they are sanctions corresponding to minor infringements imposed by the SMV that had become final in the four (4) years

PERÚ Ministerio de Economía y Finanzas

SMV Superintendencia del Mercado de Valores “Decenio de la Igualdad de Oportunidades para Mujeres y Hombres” “Año de la Esperanza y el Fortalecimiento de la Democracia” 10 Electronically signed document in the framework of Law No. 27269, Law of Digital Signatures and Certificates, its regulations and amendments. The integrity of the document and the authorship of the signature(s) can be verified at https://apps.firmaperu.gob.pe/web/validador.xhtml prior to the commission of the infringement being evaluated; (iv) The infringing subject is not recidivist; (v) The infringer has not obtained benefits from his administrative infringement; and, (vi) It has not been proven that the infringer acted with intent in the commission of the infringement; 35. That, as detailed in the evaluation of the Sanctioning Criteria, it can be stated that: (i) The impact on transparency in the market was minimal; (ii) The infringements committed have not caused a concrete harm to investors or associates, since no type of complaint or receipt of indication has been registered regarding this; (iii) The Issuer does not have antecedents of infringement corresponding to minor infringements imposed and does not have the condition of recidivist; (iv) The infringing subject has not obtained a benefit from his illegal conduct; and, (v) It has not been proven that the infringer acted with intent in the commission of the infringement; 36. That, therefore, having complied concurrently with what is stated in numeral 6.1 of the Regime of Gradual Sanctions and of the evaluation of the Sanctioning Criteria by this SASCM, it corresponds to impose on the Issuer one (01) reprimand for the non-compliance subject of the charge; 5.3 On the Recognition of Responsibility 37. That, the Issuer through a written submission of defenses expressly recognized its administrative responsibility regarding the infringement subject of the present procedure. Nevertheless, in accordance with the Sanctioning Criteria mentioned previously, it corresponds to apply the reprimand sanction regarding the infringements subject of the present procedure; therefore, as no fine sanction is determined, it lacks object to apply the fifty percent (50%) discount established in numeral 1 of letter a) of article 26 of the Sanctions Regulation, which regulates the recognition of responsibility as a mitigating circumstance of sanction, and; Being in accordance with what is provided in numerals 14 and 36 of article 43 of the Regulation of Organization and Functions of the Superintendency of the Securities Market – SMV, approved by Supreme Decree No. 216-2011-EF; RESOLVES: Article 1º.- Declare that Caja Municipal de Ahorro y Crédito Cusco S.A. has incurred one (01) infringement of a minor nature typified in numeral 3, paragraph 3.1 of Annex I of the Sanctions Regulation, approved by SMV Resolution No. 0352018-SMV/01, for having communicated late the material fact referred to the execution of a subordinate loan with Corporación Financiera de Desarrollo S.A. - COFIDE. Article 2º.- Sanction Caja Municipal de Ahorro y Crédito Cusco S.A. with one (01) reprimand for what is provided in article 1° of the present Resolution. Article 3º.- The present Resolution does not exhaust the administrative route, this being able to be challenged before this Adjunct Superintendency of Supervision of Market Conducts by filing the reconsideration appeal, administrative appeal recognized in article 207 of the Single Ordered Text of Law No. 27444, General Administrative Procedure Law, approved by Supreme Decree No. 006-2026-JUS within the period of fifteen (15) business days

PERÚ Ministerio de Economía y Finanzas

SMV Superintendencia del Mercado de Valores “Decenio de la Igualdad de Oportunidades para Mujeres y Hombres” “Año de la Esperanza y el Fortalecimiento de la Democracia” 11 Electronically signed document in the framework of Law No. 27269, Law of Digital Signatures and Certificates, its regulations and amendments. The integrity of the document and the authorship of the signature(s) can be verified at https://apps.firmaperu.gob.pe/web/validador.xhtml counted from the day following its notification, as it is a procedure of single administrative instance. Article 4º.- In case the present Resolution is not subject to challenge, it must be published on the “Institutional Page of the SMV on the Digital Platform Unique of the Peruvian State for Citizen Orientation (www.gob.pe/smv)”, in observance of what is provided by numeral 1 of article 7 of the “Policy on dissemination of normative projects, laws of general character, early agenda and other administrative acts of the SMV”, approved by Resolution SMV No. 014-2014-SMV/01, and by what is provided in the last paragraph of article 14 of the Sanctions Regulation, approved by SMV Resolution No. 035-2018-SMV/01. Article 5º.- Transcribe the present Resolution to Caja Municipal de Ahorro y Crédito Cusco S.A. Register, communicate and publish. Carlos Rivero Zevallos Adjunct Superintendent Adjunct Superintendency of Supervision of Market Conducts