Adjunct Superintendent Resolution No. 045-2025-SMV/11

PERU Ministry of Economy and Finance

SMV
Securities Market Superintendence
"Decade of Equality of Opportunities for Women and Men" "Year of recovery and consolidation of the Peruvian economy" 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. 045-2025-SMV/11 Lima, July 30, 2025 Subject: To rectify the Adjunct Superintendent Resolution SMV No. 043-2025-SMV/11 that sanctions AI INVERSIONES PALO ALTO S.A. with a (1) total fine of 4.84 UIT for having committed two (2) minor infractions typefied in subsection 3.1 of numeral 3 of
Annex I of the Sanctions Regulation.
Administered Entity: AI INVERSIONES PALO ALTO S.A.
Subject: Rectification due to material error in the Adjunct Superintendent Resolution SMV No. 043-2025-SMV/11 File No.: 2025012262 The Adjunct Superintendent of Market Conduct Supervision SEEN:
The administrative file No. 2025012262, and the Adjunct Superintendent Resolution SMV No. 043-2025-SMV/11 of July 18, 2025; CONSIDERING:

1. That, by Adjunct Superintendent Resolution SMV No. 043-2025-SMV/11 of July 18, 2025 (hereinafter, the Resolution),
   the Adjunct Superintendent of Market Conduct Supervision resolved in Article 1 of the Resolution that AI Inversiones Palo Alto S.A. committed two (2) minor infractions typified in subsection 3.1 of numeral 3 of Annex I of the Sanctions Regulation, approved by SMV Resolution No. 035-2018-SMV/01, for the late communication of (i) the material fact referred to the approval of the consolidated interim financial statements as of September 30, 2024 approved in the General Shareholders' Meeting held on November 13, 2024, and (ii) the consolidated interim financial statements as of September 30, 2024 approved in the General Shareholders' Meeting held on November 13, 2024;

PERU Ministry of Economy and Finance

SMV
Securities Market Superintendence
"Decade of Equality of Opportunities for Women and Men" "Year of recovery and consolidation of the Peruvian economy" 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
2. That, however, in Article 2 of the dispositive part of the Resolution, it stated: "Sanction AI Inversiones Palo Alto S.A., with
a total fine of 4.84 UIT equivalent to S/ 29,931.15 (Twenty-nine thousand nine hundred thirty-one and 15/100 Soles) pursuant to Article 1 of this Resolution."; regarding which it is noted that a material error has been committed, since it should say: "Sanction AI Inversiones Palo Alto S.A. with a total fine of 4.84 UIT equivalent to S/ 24,931.15 (Twenty-four Thousand Nine Hundred Thirty-one and 15/100 Soles), pursuant to Article 1 of this Resolution." (Underlining added);
3. That, the same material error has been identified in
considering 37. of the reasoning part of the Resolution (page 8), which corresponds to be rectified in the same sense as indicated in the previous considering of this Resolution;
4. That, material or arithmetic errors in
administrative acts can be rectified with retroactive effect, at any time, ex officio or at the instance of the administered entities; provided that the substance of its content nor the meaning of the decision is altered, which is verified in the present case, so it is appropriate to rectify the Resolution, regarding what is stated in the preceding paragraphs, under the protection of what is provided by Article 212 of the Unified Text of the General Administrative Procedure Law – Law No. 27444 approved by Supreme Decree No. 004-2019-JUS; and, Being in accordance with what is provided in numerals 14 and 36 of
Article 43 of the Organization and Functions Regulation of the SMV, approved by
Supreme Decree No. 216-2011-EF;
RESOLVES:
Article 1st.- To rectify the material error contained in
considering 37. of the reasoning part of the Resolution (page 8) of the Adjunct Superintendent Resolution SMV No. 043-2025-SMV/11 of July 18, 2025, the same which will be drafted as follows:
"37. That, as has been indicated, the Issuer manifested in its defenses, that it assumed its responsibility expressly and in writing for the infractions subject of charges; so that in application of the reduction of fifty percent (50%), in virtue of the recognition of responsibility within the deadline for defenses, it corresponds to impose on the Issuer the application of a total fine of 4.84 UIT equivalent to S/ 24,931.15 (Twenty-four Thousand Nine Hundred Thirty-one and 15/100 Soles) for both infractions".
Article 2nd.- To rectify the material error contained in
Article 2 of the dispositive part of the Adjunct Superintendent Resolution SMV No.
043-2025-SMV/11 of July 18, 2025, the same which will be drafted as follows:
"Article 2.- Sanction AI Inversiones Palo Alto S.A. with a total fine of 4.84 UIT equivalent to S/ 24,931.15 (Twenty-four Thousand Nine Hundred Thirty-one and 15/100 Soles), pursuant to Article 1 of this Resolution".

PERU Ministry of Economy and Finance

SMV
Securities Market Superintendence
"Decade of Equality of Opportunities for Women and Men" "Year of recovery and consolidation of the Peruvian economy" 3 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
Article 3rd.- To transcribe this Resolution to
AI Inversiones Palo Alto S.A.
Register, communicate and publish,
Carlos Rivero Zevallos
Adjunct Superintendent
Adjunct Superintendent of Market Conduct Supervision