Adjunct Superintendent Resolution No. 055-2025-SMV/11

PERÚ 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 within the framework of Law No. 27269, Law on 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. 055-2025-SMV/11 Lima, August 27, 2025 The Adjunct Superintendent of Market Conduct Supervision SEEN:
The File No. 2024043077 which contains, among others, the appeal filed by PETROLEOS DEL PERU - PETROPERU S.A. against the Adjunct Superintendent Resolution SMV No. 049-2025-SMV/11; CONSIDERING:

1. That, Article 3 of Legislative Decree No. 1683,
   Legislative Decree that establishes the deadlines for the attention of administrative appeals presented in the complex administrative sanctioning procedures of the Securities Market Superintendence (hereinafter, DLEG No. 1683), establishes that, within a maximum period of forty-five (45) business days, the Securities Market Superintendence - SMV must resolve the reconsideration appeals filed in the complex administrative sanctioning procedures;
2. That, Article 5 of DLEG No. 1683, provides that
   the determination of the high complexity of the administrative sanctioning procedure is carried out within three (3) business days of the administrative appeal being filed, through a reasoned and unappealable resolution in the administrative venue, issued by the body responsible for resolving it; and that, said period forms part of the maximum period for the resolution of the administrative appeal;
3. That, through Resolution SMV No. 013-2024-
   SMV/01, it was established that the administrative authority that resolves the reconsideration appeal may declare the high complexity of the administrative sanctioning procedure when it verifies that any of the following criteria are met: (i) There is a plurality of sanctioned parties; (ii) There is a plurality of administrative infractions; or, (iii) The administrative infraction is classified as serious or very serious in the current Sanctions Regulation (Underline added);
4. That, through Adjunct Superintendent Resolution SMV No. 049-2025-SMV/11, it was resolved to sanction PETROLEOS DEL PERU -
   PETROPERU S.A. with a fine of 10.02 Tax Units (UIT) equivalent to S/ 49,179.00 (Forty-Nine Thousand One Hundred Seventy-Nine and 00/100 Soles), for having incurred five (5) infractions of a light nature typified in paragraph 3.1 of number 3 of Annex I of the Sanctions Regulation, approved by Resolution SMV No. 035-2018-SMV/01, for the following charges: communicating in a

PERÚ 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 within the framework of Law No. 27269, Law on 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 timely manner (i) the material fact regarding the clarification of the news titled “Petro-Perú seeks to clarify Fitch Ratings observations” and “Petroperú will now seek partner to operate block 64” (Charge No. 1); (ii) the material fact regarding the clarification of the news titled “Government will give capital to Petro-Perú for US$1,000 million to reinforce its financial capacity” (Charge No. 2); (iii) the material fact regarding the dismissal of Mr. Antonio Leonardo Manosalva Alarcón as Director Representative of the Workers (Charge No. 3); (iv) the material fact regarding the main aspects contained in the Restructuring Plan (Charge No. 4); and, (v) the material fact regarding the terms of the financial support referred to in Agreement No. 087- 2023-PP(Charge No. 6);
5. That, through writing dated August 26, 2025,
PETROLEOS DEL PERU - PETROPERU S.A. filed an appeal against the aforementioned resolution;
6. That, from the review of the sanctioning resolution and the
appeal filed, it is verified that there is a plurality of administrative infractions, insofar as PETROLEOS DEL PERU - PETROPERU S.A. was sanctioned for having committed five (5) administrative infractions, for communicating in a timely manner (i) the material fact regarding the clarification of the news titled “Petro-Perú seeks to clarify Fitch Ratings observations” and “Petroperú will now seek partner to operate block 64” (Charge No. 1); (ii) the material fact regarding the clarification of the news titled “Government will give capital to Petro-Perú for US$1,000 million to reinforce its financial capacity” (Charge No. 2); (iii) the material fact regarding the dismissal of Mr. Antonio Leonardo Manosalva Alarcón as Director Representative of the Workers (Charge No. 3); (iv) the material fact regarding the main aspects contained in the Restructuring Plan (Charge No. 4); and, (v) the material fact regarding the terms of the financial support referred to in Agreement No. 087-2023-PP(Charge No. 6);
7. That, according to the legal framework cited above,
the present administrative sanctioning procedure qualifies as high complexity, so the deadline to resolve the reconsideration appeal filed is up to forty-five (45) business days; and, Being governed by the provisions of Articles 3 and 5 of Legislative Decree No. 1683, Legislative Decree that establishes the deadlines for the attention of administrative appeals presented in the complex administrative sanctioning procedures of the Securities Market Superintendence, Article 1 of Resolution SMV No. 013-2024-SMV/01 and paragraph 22 of Article 43 of the Organization and Functions Regulation of the Securities Market Superintendence, approved by Supreme Decree No. 216-2011-EF; RESOLVES:
Article 1°.- Classify the present administrative
sanctioning procedure as high complexity, according to paragraph 3 of Article 1 of Resolution SMV No. 013-2024-SMV/01.
Article 2°.- This Resolution is unappealable in the administrative
venue, according to what is established by Article 5 of Legislative Decree No.
1683, Legislative Decree that establishes the deadlines for the attention of administrative appeals presented in the complex administrative sanctioning procedures of the Securities Market Superintendence.

PERÚ 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 within the framework of Law No. 27269, Law on 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 3°.- Notify this Resolution to
PETROLEOS DEL PERU - PETROPERU S.A.
Register, communicate and publish.
Carlos Rivero Zevallos
Adjunct Superintendent
Adjunct Superintendence of Market Conduct Supervision