Adjunct Superintendent Resolution No. 032-2026-SMV/11

PERÚ Ministry of Economy and Finance

SMV
Securities Market
Superintendency
Electronically signed document within the framework of Law No. 27269, Law of Digital Signatures and Certificates, its Regulations and amendments. The integrity of the document and authorship Adjunct Superintendent Resolution SMV No. 032-2026-SMV/11 Lima, August 25, 2026 Summary: To sanction COMPAÑIA MINERA PODEROSA S.A. with a total fine of 5,992 UIT for having committed two (02) minor infractions typified in subsection 3.1 of numeral 3 of Annex I of the Sanctions Regulation Administered Entity: COMPAÑIA MINERA PODEROSA 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.: 2026024050 The Adjunct Superintendent of Market Conduct Supervision SEEN:
The administrative file No. 2026024050, containing the administrative sanctioning procedure initiated by the General Superintendency of Conduct Compliance of the Securities Market Superintendency – SMV (hereinafter, the IGCC), against Compañía Minera Poderosa S.A. (hereinafter, the Issuer); as well as Report No. 1020-2026-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 the present case–, has brought to the knowledge of the Adjunct Superintendency of Market Conduct Supervision of the SMV (hereinafter, SASCM), the PAS of administrative file No. 2026024050, with the aim that it issues a decision as the sanctioning body of single administrative instance, as appropriate for the type of infractions evaluated in said PAS. In this way, the SASCM assumes competence in

PERÚ Ministry of Economy and Finance

SMV
Securities Market
Superintendency
Electronically signed document within the framework of Law No. 27269, Law of Digital Signatures and Certificates, its Regulations and amendments. The integrity of the document and authorship observance of the exercise of the supervisory function and of the sanctioning power of the Securities Market Superintendency – SMV established through the Unified Concorded 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-11 (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 Regulation on Organization and Functions of the Securities Market Superintendency – SMV, approved by Supreme Decree No. 216-2011-EF (hereinafter, ROFSMV), in the sense that it is a specific function of the SASCM to impose sanctions in a single administrative instance. Likewise; the SASCM has the powers 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 presenting its financial information to the securities market in a timely manner;
2.2. Charges
3. That, as a result of said evaluation, through Letter No. 2585-2026-SMV/11.2 (hereinafter, Letter of Charges), charges were formulated against the Issuer for the following:
Charge 1
Late submission of the Individual Interim Financial Statements and the respective Management Report for the third quarter of 2025, which should have been submitted by October 31, 2025; however, they were submitted on November 18, 2025. (File No. 2025050724). Charge 2 Late submission of the Consolidated Interim Financial Statements for the third quarter of 2025, which should have been submitted by November 17, 2025; however, they were submitted on December 11, 2025. (File No. 2025053807);
2.3. Defenses
4. That, through a document presented on June 12, 2026, the Issuer presented its defenses stating the following:
(i) Regarding this matter, the Issuer pointed out that the late submission of the Individual Interim Financial Statements and the Management Report corresponding to the third quarter of 2025, as well as the Consolidated Interim Financial Statements of the same period, did not obey a deliberate conduct or a deliberate decision to violate its obligations as an issuer, but rather an exceptional situation originating from the migration of its processes to the SAP S/4HANA system, whose implementation process began on January 1, 2025. Likewise, it indicated that said process implied substantial changes and adaptations in its internal processes and in the management of the various areas involved,

PERÚ Ministry of Economy and Finance

SMV
Securities Market
Superintendency
Electronically signed document within the framework of Law No. 27269, Law of Digital Signatures and Certificates, its Regulations and amendments. The integrity of the document and authorship due to the incorporation of the new ERP (Enterprise Resource Planning) system. Likewise, it stated that, despite having trained its personnel, technical problems arose during the implementation due to the complexity of the system, which would have exceeded its capacity for foresight and diligence, as well as that of its specialists. In this line, it argued that the implementation of said software generated delays in the preparation of monthly financial statements from the beginning of the 2025 fiscal year, a situation that would have extended until the third quarter of said fiscal year. On this basis, the Issuer alleged that the described facts would constitute a case of force majeure, in accordance with article 1315 of the Civil Code, considering that the situation presented would constitute an extraordinary, unforeseeable and irresistible event that would have prevented the timely compliance with its obligations to present financial information. (ii) Likewise, it invoked what is established in article 3 of the Regime of Gradual Sanctions for late submission of financial information, annual report and material events, approved by SMV Resolution No. 007-2023-SMV/01 (hereinafter, Regime of Gradual Sanctions), as well as article 27 of the Sanctions Regulation approved by SMV Resolution No. 035-2018-SMV/01 (hereinafter, Sanctions Regulation), which provide for the application of exemptions from liability, including cases of fortuitous event, force majeure or other comparable exceptional situations. (iii) In view of this, it requested that the described situation be considered as a causal exemption from administrative liability, as it estimated that this made it impossible to timely comply with the obligation to present the Individual Interim Financial Statements, the Management Report and the Consolidated Interim Financial Statements corresponding to the third quarter of 2025.
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) 1, 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, 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 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 intentionality 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;

1 By Supreme Decree No. 006-2026-JUS, published on April 30, 2026 in the Official Newspaper El Peruano, the Unified Ordered Text of Law No. 27444 General Administrative Procedure Law, approved by Supreme Decree No. 006-2026-JUS, was approved.

PERÚ Ministry of Economy and Finance

SMV
Securities Market
Superintendency
Electronically signed document within the framework of Law No. 27269, Law of Digital Signatures and Certificates, its Regulations and amendments. The integrity of the document and authorship
7. That, in observance of what is provided by numeral 5 of article 235 of the TUO of the LPAG, through Letter No. 3228-2026-SMV/11 of July 10, 2026, the Report was sent to the Issuer so that it could formulate its allegations within a period of five (05) business days;
8. That, the Issuer on July 20, 2026, presented its allegations referring that it recognizes its responsibility regarding the two (02) infractions committed, for which it requests that the sanction resolution be issued in order to comply with the payment of the fines applying the reduction of thirty percent (30%) of the amount in accordance with what is established in numeral 2) of literal a) of article 26 of the Sanctions Regulation;
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 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
10. That, article 31 of the TUO of the LMV establishes that:
“What is established 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 management of the centralized mechanism, of the information that one or the other requires of it and, necessarily, that indicated next:
a) Its financial states and indicators, with the minimum information that the SMV generally indicates, with a frequency not greater than quarterly; (…)”. (Underline added);
11. That, likewise, article 9 of the Standards 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 (Standards on Preparation, Presentation and Dissemination of FS) states the following:
“Obligated subjects must prepare, present and disseminate their annual financial statements, which must be accompanied by the corresponding audit report, as well as the interim financial statements corresponding to the first, second, third and fourth quarter of the economic year (…)”. (Underline added);
12. That, with respect to individual interim financial statements, numeral 15.3 of article 15 of the Standards on Preparation, Presentation and Dissemination of FS provides that:
“April 30, July 31 and October 31 of each year and February 15 of the following year are the deadlines for the presentation of the individual or separate interim financial statements of the first, second, third and fourth quarter, respectively”. (Underline added);

PERÚ Ministry of Economy and Finance

SMV
Securities Market
Superintendency
Electronically signed document within the framework of Law No. 27269, Law of Digital Signatures and Certificates, its Regulations and amendments. The integrity of the document and authorship
13. That, likewise, with respect to consolidated interim financial statements, numeral 17.4 of article 17 of the Standards on Preparation, Presentation and Dissemination of FS states that:
“May 15, August 15, November 15 and March 1 of the following year are the deadlines established for the presentation of the consolidated interim financial statements of the first, second, third and fourth quarter, respectively (…)”. (Underline added);
14. That, furthermore, numeral 21.1 of article 21 of the Standards on Preparation, Presentation and Dissemination of FS provides the following:
“Issuers and legal entities registered in the RPMV, whose special regulation requires it, must prepare the Management Report, which must be presented together with the individual or separate interim financial statements”;
15. That, for the purpose of determining possible sanctions, infractions for communicating material events late must be noted that according to what is provided in subsection 3.1 of numeral 3 of Annex I of the Sanctions Regulation, it states that it constitutes a minor infraction:
“To present outside the established deadline, or to present it 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 events and, annual reports.” (Underline added);
16. That, according to what is established in article 35 of the Sanctions Regulation, it corresponds that these infractions be sanctioned with a reprimand or a fine not less than one (1) UIT and up to the limit of twenty-five (25) UIT;
4.2. Evaluation of the case
17. That, in the administrative file No. 2026024050, which contains the documentation of the present PAS, it is appreciated that through Memorandum No. 843-2026-SMV/11.1 of February 26, 2026 (File No. 2026008965, the General Superintendency of Conduct Supervision (hereinafter, IGSC) –the body of the Securities Market Superintendency – SMV that has within its functions and powers, the supervision of compliance with the norms applicable to issuer companies with securities registered in the RPMV, evaluating the indications of possible infractions, and sends, for its consideration, the reports of indications of infractions respectively, to the IGCC–, sent to the IGCC, the result of its evaluation, and specifically what refers to the present PAS;
18. That, it must be kept in mind that the procedures and legal forms with which the IGSC conducts its inspection and/or supervision activity, which conclude with a report of indications of infraction, determine that its pronouncement or opinion on a specific topic of supervision must necessarily be an opinion on the merits of the matter –giving the possibility that even a decision is taken, for example, the adoption of

PERÚ Ministry of Economy and Finance

SMV
Securities Market
Superintendency
Electronically signed document within the framework of Law No. 27269, Law of Digital Signatures and Certificates, its Regulations and amendments. The integrity of the document and authorship corrective measures—. Now, it must be specified that said opinion and the report of indications of infraction prepared by the IGSC are not binding for the IGCC, as established in the second paragraph of article 9 of the Sanctions Regulation 2;
19. 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 bodies or administrative instances of the SMV, functionally independent from each other and from this Office; first the IGSC which at its time reported the indications of infraction 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 for the charges subject of the present PAS;
20. That, next, it proceeds to evaluate the charges imputed:
21. That, regarding this, it corresponds to analyze the arguments and means presented by the administered entity in accordance with subsection a) of article 27 of the Sanctions Regulation, which establishes that it constitutes an exemption from liability: "The fortuitous event, the force majeure or another exceptional situation that, at the discretion of the SMV, were comparable to the fortuitous event or force majeure duly proven"; disposition concordant with numeral 1 literal a) of article 236-A of the TUO of the LPAG;
22. That, in that sense, it corresponds to determine if the non-compliance subject of the present procedure, referred to the late submission of the Individual Interim Financial Statements, Management Report and Consolidated Interim Financial Statements corresponding to the third quarter of 2025, occurred as a consequence of a situation of force majeure;
23. That, although the administrative normativity does not develop the content of force majeure as an exemption from liability, it corresponds to resort to the sources of the administrative procedure provided in numeral 2.3 of Article V of the Preliminary Title of the TUO of the LPAG, among which are the laws and dispositions of equivalent hierarchy. In this sense, article 1315 of the Civil Code is applicable, which provides that there is fortuitous event or force majeure when an extraordinary, unforeseeable and irresistible event occurs that prevents the fulfillment of an obligation;
24. That, in view of this, it corresponds to evaluate if the situation alleged by the administered entity fulfills the constitutive elements of force majeure:

“Article 9.- PRELIMINARY INQUIRIES AS A CONSEQUENCE OF SUPERVISION ACTIONS The General Superintendencies of Supervision and the Adjunct Superintendency of Risks carry out preliminary inquiries of possible infractions to the normativity under the competence of the SMV that they detect as part of their supervision functions. When said organs conclude that there are sufficient indications of possible administrative infractions they send 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, the General Superintendencies of Compliance may carry out inspections or additional investigations of the reported indications. (…)”

PERÚ Ministry of Economy and Finance

SMV
Securities Market
Superintendency
Electronically signed document within the framework of Law No. 27269, Law of Digital Signatures and Certificates, its Regulations and amendments. The integrity of the document and authorship (i) Originating from a cause foreign to the will of the obligated It must be considered that the causal fact of the force majeure must not be found within the sphere of action or domain of the Issuer, but outside its scope of control. Regarding this, the Issuer stated that the late submission of the financial information occurred due to technical problems arising during the migration and implementation process of the SAP S/4HANA system, initiated on January 1, 2025, indicating additionally that said implementation generated delays in the preparation of monthly financial statements from the beginning of said fiscal year. However, it is observed that the implementation of said computer system constitutes a management and organization decision adopted by the Issuer itself within the development of its business and operational activities. Consequently, the risks derived from said implementation and of the necessary adjustments for its functioning are within its scope of control and organization. In that sense, the circumstances alleged by the administered entity do not come from a cause foreign to its will, but are included within its sphere of domain and internal management. (ii) Unforeseeable fact For a situation of force majeure to be configured, it is required that the alleged fact be unforeseeable; that is, that it reasonably escapes from the possible scenarios that could have been anticipated by the obligated. Regarding this matter, the Issuer indicated that the implementation process of the SAP S/4HANA system began on January 1, 2025 and that the problems derived from said process caused delays in the preparation of monthly financial information from the beginning of the fiscal year, a situation that would have extended until the third quarter of 2025. From what is exposed by the Issuer itself, it is appreciated that the problems associated with the implementation of the new system had been manifesting since the beginning of the 2025 fiscal year; therefore, it could reasonably foresee that the continuity of such incidents could affect the timely compliance with its regulatory obligations to present financial information. Consequently, it is not observed that the alleged situation has the condition of unforeseeable, since the administered entity had prior information regarding the difficulties generated during the implementation of the system and the risks that these could cause regarding its informative obligations. (iii) Irresistible fact The irresistibility implies the objective impossibility of avoiding or overcoming the alleged fact even if all reasonable measures of diligence had been deployed. In the present case, considering that the Issuer had prior knowledge of the incidents associated with the implementation of the SAP S/4HANA system and of the
delays that these had been causing in the preparation of monthly financial information from the beginning of the 2025 fiscal year, it corresponded to adopt

PERÚ Ministry of Economy and Finance

SMV
Superintendencia del Mercado de Valores
Documento electrónico firmado digitalmente en el marco de la Ley N° 27269, Ley de Firmas y Certificados Digitales, su Reglamento y modificatorias. La integridad del documento y la autoría mechanisms reasonable and sufficient to mitigate such risks and ensure the timely compliance of their regulatory obligations. Indeed, the difficulties arising from a technological implementation process constitute operational risks that are part of the Issuer's internal management and organization, so this had to foresee and adopt actions aimed at minimizing potential impacts on the compliance of its information obligations before the market. In this line, the Issuer has not proven to have implemented additional measures or alternative mechanisms aimed at avoiding the impact on the presentation of the financial information subject to analysis, limiting itself to pointing out the existence of technical difficulties derived from the system implementation process. Consequently, it is not observed that the alleged facts were irresistible nor that there is an objective impossibility of avoiding their effects through the adoption of reasonable measures of foresight and management;
25. That, the Issuer through its statements presented
on July 20, 2026 acknowledged its responsibility regarding the two (02) infractions committed in accordance with numeral 2) of literal a) of article 26 of the Sanctions Regulation 3 , reasoning that will be considered to determine the infringement to be imposed;
26. That, having evaluated the arguments
formulated by the Issuer, this Adjunct Superintendency considers that it has not been proven the concurrence of the necessary constitutive elements to configure a supposed exemption from liability for force majeure, so the arguments presented do not disprove the facts subject to imputation. However, the acknowledgment of the infractions made in the statements will be assessed in the part corresponding to the determination of the sanction in this Resolution;
V. DETERMINATION OF THE SANCTION
27. That, for the purpose of determining possible
sanctions, the infractions for communicating important events late must be noted 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:
“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
part of 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

“Article 26.- MITIGATING CONDITIONS OF LIABILITY FOR INFRACTIONS The following constitute mitigating conditions of liability for infractions:
a) Express and written acknowledgment of liability by the offender, once the administrative sanctioning procedure has been initiated.
When the applicable sanction is a fine, it is reduced, taking into account the following:
(…)
2. If the acknowledgment is presented after the expiration of the deadline granted for the
presentation of defenses and before the expiration of the deadline granted to formulate allegations to the instruction report, the amount of reduction will be thirty percent (30%). (…)”

PERU Ministry of Economy and Finance

SMV
Superintendencia del Mercado de Valores
Documento electrónico firmado digitalmente en el marco de la Ley N° 27269, Ley de Firmas y Certificados Digitales, su Reglamento y modificatorias. La integridad del documento y la autoría interim individual or consolidated financial statements, management report, special audit report, important events, and annual reports.” (Underlining added);
28. That, according to what is established in article
35 of the Sanctions Regulation, it corresponds that these infractions be sanctioned with a reprimand or fine not less than one (1) UIT and up to the limit of twenty-five (25) UIT;
29. That, having determined that the Issuer has
incurred 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 for sanction graduation: (i) the sanction history of the issuer, (ii) recidivism, (iii) the circumstances of the commission of the infringement, (iv) the economic damage 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 legal good protected and (viii) the existence or not of intent in the conduct of the offender;
30. That, regarding the severity of the damage to the public
interest and/or legal good protected, the timely presentation of financial information has the purpose of allowing investors to adopt investment decisions adequately informed. In this way, investors are protected and asymmetry in access to information is reduced, therefore, the legal good protected is the transparency of the securities market, which when transgressed affects the public interest. In this sense, the infractions incurred by the Issuer affect the transparency of the securities market;
31. That, regarding the antecedents, literal a)
of article 25 of the Sanctions Regulation, states that the antecedents of the offender 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, it is not considered antecedents the commission of the same infringement in the year prior to the infringement to be sanctioned;
32. That, in the present PAS, two (02)
sanction antecedents have been identified regarding the Issuer, which are detailed below:
Table No. 1: Antecedents of the Issuer

PERU Ministry of Economy and Finance

SMV
Superintendencia del Mercado de Valores
Documento electrónico firmado digitalmente en el marco de la Ley N° 27269, Ley de Firmas y Certificados Digitales, su Reglamento y modificatorias. La integridad del documento y la autoría
33. That, regarding recidivism, it is considered
as such the commission of the same infractions those sanctions that have been imposed by the SMV for the commission of the same infringement to be sanctioned and that obtained finality within the period of one (01) year prior to the moment of the commission of the infringement to be sanctioned;
34. That, in accordance with the above, it has been verified that the
Issuer has one (01) sanction resolution that would constitute recidivism for the infringement for late presentation of financial information, as shown in the following table:
Table No. 2: Recidivism of the Issuer
35. That, regarding the circumstances of the
commission of the infringement, from the verification of the information disseminated by the issuers on the SMV Institutional Page, it is observed that the presentation of the Individual Interim Financial Statements and the Management Report corresponding to the third quarter of 2025, as well as the Consolidated Interim Financial Statements of the same period was late. This financial information should have been presented on the same day of its approval, however, its presentation was made with a delay of eighteen (18) and twenty-four (24) calendar days, respectively;
36. That, regarding the economic damage caused and the
repercussion on the market, it has not been evidenced that the non-compliance subject to charge has produced a quantifiable damage, understood as an economic damage occasioned to one or more investors;
37. That, regarding the illegally obtained benefit, it has not been proven that the infringement incurred by the Issuer has generated
an illegal benefit;
38. That, regarding the probability of detection of
the infractions, we must indicate that the financial information subject to charges is verified through the SMV's internal control systems, so it is considered that, for this type of non-compliance, the probability of detection is high and less complex, as it results as a consequence of the SMV's supervision activities;
39. That, regarding the existence or not of intent
in the conduct of the offender, it has not been evidenced that the Issuer has acted in an intentional or fraudulent manner when incurring the infractions mentioned above;
40. That, in that sense, according to the evaluation
effectuated by this Adjunct Superintendency and considering the analysis contained in the Report, it corresponds to impose as a sanction a total fine

PERU Ministry of Economy and Finance

SMV
Superintendencia del Mercado de Valores
Documento electrónico firmado digitalmente en el marco de la Ley N° 27269, Ley de Firmas y Certificados Digitales, su Reglamento y modificatorias. La integridad del documento y la autoría of 8.56 UIT 4 equivalent to S/ 45,796.00 (Forty-Five Thousand Seven Hundred Ninety-Six 00/100 Soles), according to the following detail:
(i) Regarding the late presentation of the Individual Interim Financial Statements and the respective Management Report for the third quarter of 2025, it corresponds to sanction with a fine of 3.96 UIT equivalent to S/ 21,180.65 (Twenty-One Thousand One Hundred Eighty with 65/100 Soles). (ii) Regarding the late presentation of the Consolidated Interim Financial Statements for the third quarter of 2025, it corresponds to sanction with a fine of
4.60 UIT equivalent to S/ 24,615.35 (Twenty-Four Thousand Six Hundred Fifteen with
35/100 Soles);
Acknowledgment of the infractions
41. That, having verified that the Issuer in accordance with numeral 2) of literal a) of article 26 of the Sanctions Regulation
acknowledged in an express and written manner the commission of the two (02) infractions subject of the present PAS, and that said acknowledgment was carried out after the expiration of the deadline granted for the presentation of defenses and before the expiration of the deadline granted to formulate allegations to the Report, so the amount of reduction to be applied will be thirty percent (30%);
42. That, in that sense, applying the thirty percent
(30%) reduction in the sanction, it corresponds to impose as a sanction a total fine of 5.992 UIT 5 equivalent to S/ 32,057.20 (Thirty-Two Thousand Fifty-Seven with 20/100 Soles), according to the following detail:
(I) Regarding the late presentation of the Individual Interim Financial Statements and the respective Management Report for the third quarter of 2025, it corresponds to sanction with a fine of 2.772 UIT equivalent to S/ 14,830.20 (Fourteen Thousand Eight Hundred Thirty with 20/100 Soles). (II) Regarding the late presentation of the Consolidated Interim Financial Statements for the third quarter of 2025, it corresponds to sanction with a fine of
3.22 UIT equivalent to S/ 17,227 (Seventeen Thousand Two Hundred Twenty-Seven with 00/100
Soles); 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 N° 216-2011-EF; RESOLVES:
Article 1º.- Declare that Compañía Minera Poderosa
S.A. has incurred one (01) minor infringement typified in numeral 3, paragraph 3.1 of
Annex I of the Sanctions Regulation, approved by SMV Resolution N° 035-2018-
SMV/01, for the late presentation of the Individual Interim Financial Statements and the respective Management Report for the third quarter of 2025.
Article 2º.- Sanction Compañía Minera Poderosa
S.A. with a fine of 2.772 UIT equivalent to S/ 14,830.20 (Fourteen Thousand Eight Hundred Thirty with 20/100 Soles); for what is provided in article 1° of this Resolution.

4 The Supreme Decree N° 260-2024-EF set the UIT for the 2024 exercise at S/ 5,350.00.
5 The Supreme Decree N° 260-2024-EF set the UIT for the 2024 exercise at S/ 5,350.00.

PERU Ministry of Economy and Finance

SMV
Superintendencia del Mercado de Valores
Documento electrónico firmado digitalmente en el marco de la Ley N° 27269, Ley de Firmas y Certificados Digitales, su Reglamento y modificatorias. La integridad del documento y la autoría
Article 3º.- Declare that Compañía Minera Poderosa
S.A. has incurred one (01) minor infringement typified in numeral 3, paragraph 3.1 of
Annex I of the Sanctions Regulation, approved by SMV Resolution N° 035-2018-
SMV/01, for the late presentation of the Consolidated Interim Financial Statements for the third quarter of 2025.
Article 4º.- Sanction Compañía Minera Poderosa
S.A. with a fine of 3.22 UIT equivalent to S/ 17,227 (Seventeen Thousand Two Hundred Twenty-Seven with 00/100 Soles); for what is provided in article 3° of this Resolution.
Article 5º.- This Resolution does not exhaust the administrative
path, 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 N° 27444, General Administrative Procedure Law, approved by Supreme Decree N° 006-2026-JUS, within the period of fifteen (15) business days counted from the day following its notification, as it is a procedure of single administrative instance. In case this Resolution is not challenged, it may avail itself of the regime of reduction of the corresponding sanction.
Article 6º.- In case this Resolution is not
subject to challenge, it must be published on the “SMV Institutional Page on the Unified Digital Platform 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 diffusion of normative projects, legal norms of general character, early agenda and other administrative acts of the SMV”, approved by Resolution SMV N° 014-2014-SMV/01, and by what is provided in the last paragraph of article 14 of the Sanctions Regulation, approved by SMV Resolution N° 035-2018-SMV/01.
Article 7º.- Transcribe this Resolution to
Compañía Minera Poderosa S.A.
Register, communicate and publish.
Carlos Rivero Zevallos
Adjunct Superintendent
Adjunct Superintendency of Supervision of Market Conducts