Adjunct Superintendent Resolution No. 056-2025-SMV/11 — SMV — PE

That, the administrative file No. 2024048178
contains the documentation and information regarding an administrative sanctioning procedure (hereinafter, PAS), which has been brought to the knowledge of the SASCM in observance of the exercise of the supervision function and of the sanctioning faculty of the Securities Market Superintendence – SMV, established through the Text PERÚ Ministry of Economy and Finance SMV Securities Market Superintendence "Decade of Equal Opportunities for Women and Men" "Year of recovery and consolidation of the Peruvian economy" 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 Unified Concordat of its Organic Law, Decree Law No. 26126 (hereinafter, Organic Law of the SMV), and the Unified Ordering Text of the Securities Market Law, Legislative Decree No. 861, approved by Supreme Decree No. 020-2023-EF, 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 Superintendence, aproved 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 regarding timeliness in the presentation of periodic and eventual information, whose compliance control corresponds to the SASCM, in addition to resolving reconsideration appeals that are filed against the pronouncements it issues in single instance administrative;
II. FACTS
That, through the Impugned Resolution, the SASCM
resolved:
"Article 1st.- Declare that Refinería La Pampilla S.A.A. has incurred three (3) minor infractions, typified in subsection 3, numeral 3.1 of
Annex I of the Sanctions Regulation, approved by Resolution SMV No. 035-
2018-SMV/01 for the late presentation of the following important facts: i) the oil spill at the facilities of Terminal Multiboyas No. 2 occurred on January 15, 2022, ii) the start of the administrative sanctioning procedure by OEFA against the Issuer for having failed to comply with the preventive measure to identify the zones affected by the displacement of the hydrocarbon that was notified on January 27, 2022, and iii) the start of the administrative sanctioning procedure by OEFA against the Issuer for having failed to comply with the preventive measures referred to carrying out cleaning, containment and recovery actions of the floating hydrocarbon in the sea of Ventanilla, which was notified on February 08, 2022.
Article 2nd.- Sanction Refinería La Pampilla S.A.A. with a total fine of
6 UIT equivalent to S/ 27,600.00 (Twenty-seven Thousand Six Hundred and 00/100 Soles), for what is provided in article 1° of this Resolution.
Article 3rd.- This Resolution does not exhaust the administrative route, this being
impugnable before this Adjunct Superintendency of Supervision of Market Conducts through the filing of the reconsideration appeal, administrative appeal recognized in article 218 of the Unified Ordering Text of Law No. 27444, General Administrative Procedure Law, approved by Supreme Decree No. 004-2019-JUS, within the term of fifteen (15) business days counted from the day following its notification, since it is a procedure of single administrative instance. In case this Resolution is not impugned, it may be subject to the regime of reduction of the corresponding sanction. (…)" (Underlined and emphasis added);
That, through writing presented on August 13, 2025, the Issuer filed an appeal against the Impugned Resolution;
That, in that sense, through Memorandum No. 3489-
2025-SMV/11 of August 25, 2025, the Office of the SASCM requested the IGCC

1 "Article 43°.- Specific functions of the Adjunct Superintendency of Supervision of Conducts of Markets:
(…)
14. Impose sanctions in single administrative instance for the commission of infractions regarding
timeliness in the presentation of periodic and eventual information, whose compliance control corresponds to the Adjunct Superintendency of Supervision of Conducts of Market; (…)". 2 "Article 218. Administrative appeals
218.1 The administrative appeals are:
a) Reconsideration appeal b) Appeal
Only in case that by law or legislative decree it is expressly established, the interposition of the administrative review appeal is possible.
218.2 The term for the interposition of the appeals is fifteen (15) peremptory days, and they shall
be resolved within thirty (30) days".
3 "Article 219.- Reconsideration appeal
The reconsideration appeal will be filed before the same body that issued the first act that is matter of the impugnation and must be supported by new evidence. In cases of administrative acts issued by bodies that constitute single instance no new proof is required. This appeal is optional and its non-interposition does not prevent the exercise of the appeal right." 4 "Article 221.- Requirements of the appeal The appeal writing must indicate the act from which one appeals and will fulfill the other requirements provided in article 124."

PERÚ Ministry of Economy and Finance
SMV
Securities Market
Superintendence
"Decade of Equal Opportunities for Women and Men" "Year of recovery and consolidation of the Peruvian economy" 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 reconsideration must be presented within the term of fifteen (15) days of communicated the impugned administrative act. In the present case, it is appreciated that the Impugned Resolution was notified to the Issuer on July 18, 2025 and the reconsideration appeal was filed on August 13, 2025; that is, within the legal term established;
11. That, it must be indicated that the other requirements for the
interposition of the reconsideration appeal, established by article 221 concordant with article 124 5 of the TUO of the LPAG, have been verified and fulfilled; so that the evaluation of this reconsideration appeal proceeds;
4.2 OFFICIAL CHANNELING
12. That, article 223 of the TUO of the LPAG establishes
that an error in the qualification of the appeal does not constitute cause to stop processing it;
13. That, numeral 3 of article 86 of the TUO of the LPAG
contemplates that every authority has the faculty to apply the figure of channeling when it detects any error or omission by the administered;
14. That, in the writing presented by the Issuer on August 13
of 2025, it can be observed that he named his pretension as appeal and indicates that in the event that the first instance refuses to elevate his appeal, he requests that the Superintendent of the SMV declare the nullity ex officio of the Impugned Resolution, as detailed below:
"AS A PREVIOUS ISSUE: POSSIBILITY OF FILING AN APPEAL REGARDING THE THREE INFRACTIONS" "The Sanctioning Resolution incurs in the error of determining that the three (3) minor infractions can only be discussed and resolved in a single instance administrative, by erroneously considering that they are infractions in which the sanction to impose for having revealed late information that would qualify as an important fact.";
15. That, the Issuer, in addition, indicates that:
"(…) it is not admissible in our legal order that the administered be deprived of the right to have reviewed in the superior instance the decision adopted in the administrative seat, simply because the first instance has decided to use an incorrect typification and that does not correspond to the facts". Adding that "In this case it is clear that what must prevail is the substance over the form, avoiding any obstacle born from a merely formalist position so that the right of defense of the issuers of the securities market is respected and for that to question in second instance in the administrative seat decisions that do not refer to a mere late delivery of information, as is the case here". "In such sense, we invoke to the first instance to observe the Principle of Legitimate Exercise of Power, provided in numeral 1.17 of Article IV of the Preliminary Title of the TUO LPAG and to avoid affecting our right to challenge their decision in a superior instance in the administrative seat based on a mere formalism to which we would have led by their own decision". "Therefore, it would not be understandable the insistence regarding that the infractions alluded are of single instance, depriving us of a mechanism of opposition before the superior instance that, according to what he expresses, the law confers upon us, and severely limiting our right of defense. It is evident that proposing a reconsideration appeal, as the only possibility of exercise of the right of defense in the administrative seat means depriving us of said right in such seat and obliging us to incur in the costs involved of going to a judicial process, which would make economically unviable the exercise of such right. Likewise, such action would eliminate the capacity of the SMV to be able to review its decisions and avoid that the same must eventually have to be discussed in the Judicial Power, thereby avoiding the use of public resources that should be destined to more beneficial ends for society. Therefore, in the supposed denied case that the first instance refuses to elevate the present appeal, as it legally corresponds, and to allow the superior instance to evaluate its decision, we request said superior instance, that is to say the Superintendent of the Securities Market Superintendence to declare the nullity ex officio of the Sanctioning Resolution, for the arguments that are included in the present".
16. That, in the writing presented, the Issuer concludes:
"We request that the Adjunct Superintendency of Supervision of Conducts of Markets of the SMV please admit to processing the present appeal and elevate it to the Superintendent of the Securities Market, instance in which it must LEAVE WITHOUT EFFECT the sanctions imposed by the Adjunct Superintendent Resolution SMV No. 042-2025-SMV/11";
17. That, as it is seen, the arguments presented
by the Issuer have as pretension that the SASCM does not know the impugnant appeal presented, since according to its argumentation, if it were so, it would be depriving him of a mechanism of opposition before the superior instance that, according to what he expresses, the law confers upon him, and would severely limit his right of defense; therefore, he requests that the files be sent to the Superintendent of the Securities Market for resolution;
18. That, according to the Impugned Resolution, the

"Article 14.- SANCTIONING BODIES
Sanctions are imposed in the first instance by the Assistant Superintendent of Prudential Supervision and the Assistant Superintendent of Market Conduct Supervision, each within the scope of their competence. Regarding infringements solely for non-compliance with regulations on the timeliness of submitting periodic or occasional information and with regulations on the protection of minority shareholders of open joint-stock companies, referred to in Annex XIV, the Assistant Superintendent of Prudential Supervision and the Assistant Superintendent of Market Conduct Supervision act as the sole administrative instance, as applicable. Their pronouncement exhausts the administrative route. (…)." (Underlining and emphasis added). 7 See the following link: https://www.tc.gob.pe/jurisprudencia/2003/00010-2001-AI.html

PERU Ministry of Economy and Finance
SMV
Securities Market
Superintendency
"Decade of Equality of Opportunities for Women and Men" "Year of recovery and consolidation of the Peruvian economy" Electronically signed document within the framework of Law No. 27269, Law of Digital Signatures and Certificates, its Regulations and modifications. The integrity of the document and the authorship of the signature(s) can be verified at https://apps.firmaperu.gob.pe/web/validador.xhtml at one point it might be further reviewed, at least, by a superior judicial body. In the Tribunal's view, after the conceptualization of the right to due administrative procedure expressed by the defendant, there underlies a mistaken idea of the configuration and justification of the administrative route. Indeed, taken to the absurd, with it implicitly ends up affirming that the claims of the administered against the State have their primary and natural scope of solution in the administrative procedure and, only subsidiarily, in the scope of the judicial process, when, in principle, every administrative resolution is susceptible to being challenged in a jurisdictional venue. Evidently, this is an interpretation that has no relation to the principle of the rule of law, which, as stated, guarantees individuals that the solution of their conflicts –with the State or with other private parties– can be elucidated before a competent, independent and impartial court of justice. It is in relation to the third impartial party, that is, with reference to the judicial body, that the legislator must guarantee the existence, at least, of a duality of conflict resolution instances, as well as the appropriate (appeal) means to enable access. Naturally, administrative bodies and tribunals do not satisfy those conditions of impartiality and independence, since they are entities that either form part of the organizational structure of the body whose administrative act is claimed, or generally belong to the Executive Power. Precisely because administrative bodies do not meet those minimum guarantees that the entity resolving the conflict must observe, is why, at the time of considering the exhaustion of the administrative route as a right of the individual [a right that translates into avoiding him access to ordinary justice if he can resolve his conflict with the state administration in that venue], said route, when its mandatory exhaustion is fixed, must be contemplated in such a way that it cannot be considered a privilege of the State or, perhaps, as a measure that unreasonably and disproportionately dissuades, makes impossible or prevents the individual from accessing a court of justice. In this sense, the Constitutional Tribunal considers that, if the legislator provides for the obligatoriness of exhausting the administrative route, a requirement derived from the right of access to justice is that it be configured in the briefest manner possible, since in this way the pro actione principle is better optimized.";
26. That, with regard to the argument of the Issuer regarding
that "the admission of the claims of the administered should be privileged with respect to aspects of a formal nature, especially if what is sought is to protect their right to challenge the decisions of the administration in the administrative venue"; it corresponds to indicate that this argument, which seeks to disregard the legal order on competences and instances provided by the ROF-SMV, previously indicated, cannot be accepted;
27. That, the principle of legality obliges the
Public Administration to act with strict adherence to the applicable normative framework, in this case, article 43, numbers 13 and 14 of the ROF and article 14 of the Regulation of

PERU Ministry of Economy and Finance
SMV
Securities Market
Superintendency
"Decade of Equality of Opportunities for Women and Men" "Year of recovery and consolidation of the Peruvian economy" Electronally signed document within the framework of Law No. 27269, Law of Digital Signatures and Certificates, its Regulations and modifications. The integrity of the document and the authorship of the signature(s) can be verified at https://apps.firmaperu.gob.pe/web/validador.xhtml Sanctions. This means that there is no second administrative instance for such infringements, and therefore, an appeal resource is not appropriate against the sanctioning resolution issued by the SASCM in these cases. The principle of legality requires that every act of the Public Administration be based on a prior norm that expressly allows it. Applying the appeal procedure in a case in which the norm provides for a single instance would not only be contrary to said principle, but would imply an act outside the competence of the SMV, which would generate an invalid administrative act;
28. That, according to this, processing the Issuer's written submission
as an appeal resource, when it does not correspond, would affect the validity of the PAS. In consequence, the authority cannot, under the argument of an extensive interpretation in favor of the administered in defense of the principles of due procedure, of informality or of efficacy, disregard the material and competence limits that the legal framework imposes;
29. That, with regard to the argument presented by the
Issuer regarding that "we invoke the first instance to observe the Principle of Legitimate Exercise of Power, provided in number 1.17 of Article IV of the Preliminary Title of the TUO LPAG and to avoid affecting our right to challenge its decision in a superior instance in the administrative venue based on a mere formalism to which its own decision would have led us"; it must be indicated that this principle is not admissible, rather this principle reaffirms that the SASCM has exercised and continues to exercise solely and exclusively the competences attributed to it in the already established norms, therefore, it lacks support to invoke this Principle alleging that if this resource is not processed as an appeal, its right to challenge would be affected, given that the guarantee offered by the rule of law is not that complaints between private parties and the State or its organs are resolved in the administrative venue, but, rather, before an impartial third party (Judicial Power) previously predetermined by law, as has established the Constitutional Tribunal in Exp. N° 0881-2003-AA/TC 8 has stated the following:
"(…) the right to plurality of instances is a guarantee consubstantial to the right to due jurisdictional procedure, which is not necessarily applicable in the scope of due administrative procedure. Through this right it is sought that what is resolved by a first instance judge can be reviewed by a functionally superior body, and in that way allow what is resolved by that one, at least, to be subject to a double jurisdictional pronouncement. The constitutional requirement to establish functionally and organically a double instance of resolution of jurisdictional conflicts is directly connected with the scope that the pronouncement emitted by the last instance legally established is capable of acquiring: the immutability of res judicata. The pronouncement that an administrative body may emit is not in the same situation, even if –the one issuing it– is of maximum hierarchy, given that in any case it is possible that such resolutions be challenged in the jurisdictional scope. In this sense, this Tribunal must recall that the guarantee offered by any rule of law is not that complaints between private parties and the State or

8 See the following link: https://www.tc.gob.pe/jurisprudencia/2004/00881-2003-AA.html

9 «Article 223.- Error in classification
An error in the classification of the resource by the appellant will not be an obstacle to its processing provided that its true character is deduced from the written submission.» 10 «Article 86.- Duties of authorities in procedures Are duties of authorities regarding the administrative procedure and its participants, the following: (...)
3. Channel the procedure ex officio, when it detects any error or omission by the administered,
without prejudice to the actions that correspond to them.»

PERU Ministry of Economy and Finance
SMV
Securities Market
Superintendency
"Decade of Equality of Opportunities for Women and Men" "Year of recovery and consolidation of the Peruvian economy" Electronically signed document within the framework of Law No. 27269, Law of Digital Signatures and Certificates, its Regulations and modifications. The integrity of the document and the authorship of the signature(s) can be verified at https://apps.firmaperu.gob.pe/web/validador.xhtml regular procedure; and it is not immersed in any of the causes of nullity dispensed in article 10 of said normative body. Likewise, it is observed that in the processing of the present PAS the principles governing it have been respected as legality, reasonableness, due procedure and presumption of validity, without any defect configuring that affects the efficacy or legitimacy of the act subject to challenge, so no nullity defects are observed in this PAS, which the Issuer alleges;
35. That, in that sense, the appeal resource
presented by the Issuer has been re-channeled ex officio; and, therefore, will be evaluated as a reconsideration resource;
4.3 EVALUATION OF THE RECONSIDERATION RESOURCE
36. That, next, it proceeds to analyze and evaluate
each of the arguments contained in the impugnative resource presented by the Issuer:
A. WITH REGARD TO THE LATE COMMUNICATION OF THE MATERIAL FACT REFERRED TO THE OIL SPILL (INFRINGEMENT 1) In this aspect of its resource, the Issuer reiterates that, even as of January 20, 2022, it lacked sufficient information to qualify the oil spill occurring on January 15, 2022 as a material fact. Indicating the following: "(…) still at the moment of communicating the Spill as a material fact, on January 20, 2022, clear information was not available about the magnitude of the same, the potential damage it could generate, the cost of an eventual repair of such damage, nor about who the responsibility was attributable to. (…) as of January 20, 2022, it did not correspond to report on the Spill under the modality of material facts." However, such argument was explicitly analyzed in letter A) of considering 31 of the Challenged Resolution, in which it was concluded that the spill could not be considered an event of minor relevance. In said resolution it was highlighted that: "(…) it entailed for the Issuer allocating human, logistical and economic resources for the immediate attention of the effects of the spill. The Issuer itself recognized the significance of the facts, by disseminating on its corporate website the Communication of January 20, 2022, (…) where it states that since the accident occurred, the contingency plan was activated and deployed a series of actions that included: i) closing the valves, which allowed stopping the pumping operation, ii) assigning a team of divers to explore the underwater damage, iii) constant monitoring, aerial, maritime and terrestrial, to evaluate the impact generated after the fact occurred, among others (…)". (Added underlining). However, the Issuer insists that the allocation of human resources, logistical and economic, the dissemination of the corporate communication of January 20, 2022, as well as media and social network coverage, constitute factors "circumstantial", inherent to its activity, which would not evidence –in its opinion– the existence of an impact that could affect its sustainability nor the capacity of a "sensible investor" to adopt informed decisions. Nevertheless, this argument is not acceptable, since such elements do not constitute isolated facts

PERU Ministry of Economy and Finance
SMV
Securities Market
Superintendency
"Decade of Equality of Opportunities for Women and Men" "Year of recovery and consolidation of the Peruvian economy" Electronically signed document within the framework of Law No. 27269, Law of Digital Signatures and Certificates, its Regulations and modifications. The integrity of the document and the authorship of the signature(s) can be verified at https://apps.firmaperu.gob.pe/web/validador.xhtml but objective indicators of the magnitude and relevance of the event from the very moment of its occurrence. In that sense, in accordance with article 3 of the Regulation of Material Facts, the duty to inform is configured when a fact has the capacity of significant influence on the Issuer or on its values, without it being necessary that the economic, operational or reputational consequences are fully determined. Thus, the immediate activation of contingency plans and the mobilization of human, technical and logistical resources demonstrate that the event was of such magnitude that it had the potential to influence significantly in society and in the perception of investors. With regard to the Issuer's reference to the "sensible investor" standard, it is worth clarifying that, according to the Resolution of the CONASEV Tribunal No. 032-2002- EF/94.12, this standard refers to investors who, although not professionals in the market, have sufficient capacity to understand the available information, weigh risks reasonably and dedicate prudent time to analyze their investment decisions. Under this criterion, the information that issuers disseminate must be clear, complete and timely, so that this investor can adequately evaluate the impact of the facts on the Issuer and on the value of its securities. According to this, in the present case, the oil spill –by its magnitude, immediate activation of contingency plans, media coverage and intervention of competent authorities– constituted, from the beginning, a fact with capacity to significantly influence the valuation of the operational risk, financial and reputational of the Issuer. Consequently, the late communication of the fact limited the access of the sensible investor to relevant and timely information for making informed decisions. Complementarily, the Issuer alleges that there was –nor exists– affectation to its sustainability, affirming that: "(…) there were (nor exist) elements to sustain that the Spill could affect the sustainability of our company, as established in number 35 of Annex 1 of the Regulation of Material Facts, so it was clear that it did not correspond to send a material fact regarding it." Regarding this, number 35 of Annex 1 of the Regulation establishes that material facts are those "(…) that may affect the sustainability (…)" of the Issuer, which does not require the materialization of a significant affectation, but only the potentiality that the fact influences in a relevant manner in society or in its values. In this line, the immediate media coverage, the intervention of
various competent authorities and the actions deployed by the company since January 15 of 2022 constitute clear and objective indications that the event met said potentiality. It is also worth highlighting that in Question 14 of the Corporate Sustainability Report corresponding to the 2022 exercise, the society itself recognizes expressly the existence of a material controversy derived from the spill as appreciated below in Image No. 1 11 . Image No. 1: Question 14 of the Sustainability Report of the 2022 exercise of the Issuer Consequently, this recognition evidences that the spill not only generated financial and operational impacts, but also a significant reputational affectation derived from controversies with directly impacted populations, thus reinforcing the position adopted in the Challenged Resolution regarding the nature and relevance of the event. Consequently, the arguments presented by the Issuer in this aspect of the resource do not provide new or different elements that allow modifying what was resolved. On the contrary, the verified actions, the public evidence and the information provided by the society itself in its sustainability report confirm that, from January 15, 2022, the duty to inform promptly the spill as a material fact was configured, in accordance with articles 3 and 4 of the Regulation of Material Facts. Additionally, it is worth highlighting that through a material fact of August 29, 2025 (File No. 2025038349) 12 the Issuer has communicated a new material fact linked to the oil spill occurring on January 15, 2022, indicating the archiving of the criminal process instituted on occasion of the referenced oil spill, through Resolution No. 47 of the Court of

11 File No. 2023013181. See the following link:
https://www.smv.gob.pe/ConsultasP8/temp/FichaRS_29901_20230328184811.pdf 12 https://www.smv.gob.pe/ConsultasP8/temp/HdI%20Archivamiento%20del%20proceso%20penal.pdf

PERU Ministry of Economy and Finance
SMV
Securities Market
Superintendency
"Decade of Equal Opportunities for Women and Men" "Year of recovery and consolidation of the Peruvian economy" 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 the authorship of the signature(s) can be verified at https://apps.firmaperu.gob.pe/web/validador.xhtml In view of the above, this agreement implied the recognition of a civil compensation amounting to USD 182,162,423.50 in favor of the Peruvian State, as compensation for the environmental damages caused by the spill, which further reinforces the conclusion that the event had, from the beginning, a potentially significant impact on the economic and reputational sustainability of the Issuer, as well as on market perception and that of a reasonable investor. The magnitude of the civil compensation amount assumed by the Issuer, together with the outcome of the criminal process, evidences the scale of the event and reaffirms that it should have been reported promptly under the modality of material event, in accordance with article 3 and paragraph 35 of Annex 1 of the Material Events Regulation. Therefore, it corresponds to dismiss the reconsideration appeal regarding the infraction linked to the late communication of said material event. B. REGARDING THE LATE COMMUNICATION OF THE MATERIAL EVENTS REFERRED TO THE INITIATION OF ADMINISTRATIVE SANCTIONING PROCEEDINGS BY OEFA (INFRACTIONS 2 AND 3) Regarding this matter, the Issuer maintains that the initiation of the PAS does not qualify as material events, and thus stated when communicating these events through the channel of material events, in compliance with a specific request made by the SMV. Likewise, it points out that the Impugned Resolution has not identified concrete qualitative elements justifying the materiality of the PAS; therefore, the Impugned Resolution fails to meet its duty to motivate the adopted measure and the imposed sanctions must be left without effect. On this particular point, in letter B) of consideration 31 of the Impugned Resolution, the SASCM pronounced itself stating the following:
“(…) it is necessary to indicate that to evaluate whether an event has sufficient materiality to constitute a material event, i.e., to weigh its capacity to generate a significant influence both on the decisions of a reasonable investor and on the price or liquidity of securities, two types of elements would have to be taken into account: (i) quantitative, related to their economic impact on the Issuer's equity, results and financial situation; and (ii) qualitative, which, although they cannot be expressed numerically, are relevant for the Issuer's business or commercial position, promoting better practices in transparency and information disclosure in the securities market. (...) In the present PAS, it has been observed that the infraction attributed to the Issuer, referred to the late communication of a material event regarding the start of the PAS by OEFA for having failed to comply with the preventive measure requiring identifying the zones affected by the displacement of the hydrocarbon spilled during unloading activities at Terminal Multiboyas No. 2; said procedure was resolved by OEFA through Directorial Resolution No. 1017- 2022-OEFA/DFAI, issued on July 11, 2022, in which the administrative responsibility of the Issuer was declared for the mentioned infringing conduct, imposing a fine of

PERU Ministry of Economy and Finance
SMV
Securities Market
Superintendency
"Decade of Equal Opportunities for Women and Men" "Year of recovery and consolidation of the Peruvian economy" 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 the authorship of the signature(s) can be verified at https://apps.firmaperu.gob.pe/web/validador.xhtml 1,087.933 UIT. Although this resolution was appealed, it is considered that at that time, this sanction had a significant impact, as stipulated in article 3 of the Material Events Regulation. Likewise, the infraction related to the late communication of the material event regarding the start of the PAS by OEFA for the non-compliance of preventive measures referred to carrying out actions cleaning, containment and recovery of the floating hydrocarbon in the sea of Ventanilla; said procedure was resolved through Directorial Resolution No. 1740-2022- OEFA/DFAI, dated October 27, 2022, in which the administrative responsibility of the Issuer was declared, imposing a fine of 6,340.082 UIT. Although also appealed, this resolution was confirmed by Resolution No. 411-2024- OEFA/TFA-SE, which not only represents a qualitative and quantitative impact on the Issuer, but also the event in question has the capacity to significantly influence the market and its equity, as established in article 3 of the Material Events Regulation, because since the confirmation of the fine sanction imposed by OEFA on the Issuer, the imposition of the fine not only generates qualitative or quantitative impacts on the financial part of the Issuer, but also, a reputational prejudice and in the sustainability variables inherent to the hydrocarbon business where the Issuer participates. In accordance with the above, the qualitative and quantitative elements of its materiality are supported in the points exposed above, which allows concluding that the late communication of these material events does have the capacity to influence significantly the investment decisions of a reasonable investor or on the price or liquidity of securities. Consequently, the start of the two (2) administrative sanctioning procedures by OEFA if implied an impact on the Issuer's equity, and had an impact on the transparency and integrity of the securities market, affecting its reputation, business and activities.” Additionally, regarding the Issuer's argument that the criteria of liquidity, price or market quotation do not apply in this case, given that the Issuer's shares are not traded in any market, but only are registered in the Public Registry of the Securities Market - RPMV, it is necessary to indicate that this argument was already evaluated in letter B) of consideration 31 of the Impugned Resolution, in which the SASCM pronounced itself stating the following:
“Regarding the argument presented by the Issuer referring to that its shares are not listed nor traded on stock exchange or in any market; it is necessary to indicate that although the Issuer's securities to date do not cotize nor trade in stock exchange round, it must be taken into account that its securities are registered in the RPMV, therefore, it must observe and comply with the communication and information revelation regime 13 concerning the prompt communication of material events.”

13 «Article 1.- Purpose

PERU Ministry of Economy and Finance
SMV
Securities Market
Superintendency
"Decade of Equal Opportunities for Women and Men" "Year of recovery and consolidation of the Peruvian economy" 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 the authorship of the signature(s) can be verified at https://apps.firmaperu.gob.pe/web/validador.xhtml On the other hand, the Issuer states that the Impugned Resolution fails its duty of motivation of the acts it issues, since it expressly refers to the supposed prejudicial impact of such procedures, but in doing so describes only the moment when a sanction is imposed on our company, noting that such effect occurs (supposedly) at the moment when the sanction is imposed, which evidences the lack of arguments to support that such an effect could exist at the moment of their initiation, which is the opportunity when our conduct is sanctioned, therefore, it states that it is not admissible for these effects that we impose a sanction based on future and uncertain facts, performing hence an ex post analysis that is not admitted by the regulations for such effects. Regarding this, as previously noted, in the present PAS it has been imputed to the Issuer, the late communication of two (02) material events referred to: (i) start of the PAS by the Environmental Evaluation and Control Agency - OEFA against the Issuer for having failed to comply with the preventive measure of identifying the zones affected by the displacement of the hydrocarbon, and (ii) the start of the PAS by OEFA against the Issuer for having failed to comply with the preventive measures referred to carrying out cleaning, containment and recovery actions of the floating hydrocarbon in the sea of ventanilla. On this particular point, it is necessary to specify that article 40 of the Regulation of Administrative Measures of OEFA, approved by Board Resolution No. 007-2015-OEFA/CD and modified by Board Resolution No. 019-2021-OEFA/CD, expressly establishes that non-compliance with a preventive measure constitutes an administrative infraction of a general and very serious nature, punishable by up to four thousand (4,000) UIT. Consequently, the non-compliance with each of the preventive measures attributed to the company could give rise, independently, to sanctions of significant magnitude. In this sense, we must note that the start of PAS by OEFA constitutes, in itself, an event with the capacity to influence investor decisions. This is due to the fact that such circumstance reveals the existence of an official investigation underway for alleged serious environmental non-compliances, which constitutes a certain, actual and material risk for the company, whose eventual realization could translate into sanctions of considerable economic and reputational impact. Likewise, although the Issuer alleges that it is not admissible that the Administration imposes a sanction based on future and uncertain facts that
eventually could affect the Issuer, it must be highlighted that the company itself recognizes the materiality of administrative sanctioning procedures initiated against it in the framework of the oil spill at sea in the installations of Terminal Multiboyas No. 2, by revealing it in its Annual Financial Statements for the 2022 exercise, Note 32 named Contingencies, in which it states the following:

PERU Ministry of Economy and Finance
SMV
Securities Market
Superintendency
"Decade of Equal Opportunities for Women and Men" "Year of recovery and consolidation of the Peruvian economy" 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 the authorship of the signature(s) can be verified at https://apps.firmaperu.gob.pe/web/validador.xhtml “Regarding the procedures initiated by the main regulatory bodies:
OEFA, Energy and Mining Investment Supervisory Body - OSINERGMIN, General Directorate of Captaincies and Coast Guard - DICAPI, National Service of Protected Natural Areas by the State - SERNANP, National Forest and Wildlife Service - SERFOR, the Company has been presenting its defenses and attending the requirements of the authorities. As of December 31, 2022, the Company is facing 19 administrative sanctioning procedures initiated by Peruvian authorities, in addition to the imposition of coercive fines and mandates of a particular nature, which include sanctions ranging from 1 UIT to 10,000 UIT in some processes. Most of the administrative sanctioning procedures are ongoing, and their results will depend on the conclusions obtained from the investigations being carried out by the corresponding authorities. On the other hand, there are some procedures where a negative result is foreseen for a total of USD25,409, whose amount has been included in the expense record of the incident at TM2 as of December 31, 2022.” (Underlining added). This recognition reveals, beyond doubt, that even the Issuer itself considers that the initiated PAS constitute relevant contingencies and risks material, whose potential realization directly affects its equity and financial situation. Therefore, it is not coherent that the Issuer attempts to minimize its impact ignoring this materiality. In accordance with the above, the obligation to inform through a material event arises from the moment the start of the PAS is notified, and not only when a final sanctioning resolution is issued. Precisely because the purpose of securities market regulation is that investors have timely access to relevant information about contingencies that may affect the equity, businesses or activities of the Issuer, thus guaranteeing transparency and integrity of the market. Consequently, the argument that the obligation to inform only activates with the imposition of a definitive sanction is not acceptable, as it would empty the preventive and transparency purpose of the material events regime. Additionally, the Issuer states that the Material Events Regulation, in its Annex 1, paragraph 16, contains a quantitative reference regarding when, an equity impact may qualify as a material event: “16. Acquisition, alienation or restructuring of assets and/or liabilities for significant amounts, 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%.”. Regarding this, the Issuer indicates that in the first procedure, the imposed fine is equivalent to 0.21% of the company's net equity and that, according to the audited financial statements of the Issuer as of December 31, 2021, its equity amounted to US$ 623,925,000. In the same way, in the second procedure, the fine represented approximately 1.2% of the company's net equity, considering the same factors. Therefore, for them it is not possible that, a

PERU Ministry of Economy and Finance
SMV
Securities Market
Superintendency
"Decade of Equal Opportunities for Women and Men" "Year of recovery and consolidation of the Peruvian economy" 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 the authorship of the signature(s) can be verified at https://apps.firmaperu.gob.pe/web/validador.xhtml impact on the company's net equity of 9%, for example, does not qualify as a material event, and the possibility of being fined, which affects the equity by 0.21% and 1.2% does qualify as a material event. In accordance with this, it is necessary to specify that the percentage provided in paragraph 16 of Annex 1 of the Material Events Regulation; that is, the reduction of net equity in an amount equal to or greater than 10%, is circumscribed to specific events linked to “investment plans and financing structure” that the Issuer carries out as established by the Material Events Regulation. Therefore, attempting to analogously apply this percentage threshold to situations different from those provided for in the norm implies an extensive interpretation of a materiality criterion designed for events of a specific nature, which would be incompatible with the principle of legality previously developed. In this sense, the fact that in certain cases a quantitative reference has been provided (such as 10% of net equity in cases of asset or liability restructuring) does not mean that such parameter must be used as a general rule of materiality for all material events. Finally, the Issuer states in its writing that this situation affects legal certainty regarding the way securities market regulation is applied concerning the obligations corresponding to issuers, due to the absolute absence of parameters that could guide when the start of a PAS should be reported as a material event. Regarding this, it is worth specifying that the applicable normative framework contained in the Material Events Regulation does not suffer from an absence of parameters, but establishes a system that combines rules with discretionary valuation criteria, which is important so that the obligation to inform can adapt to the wide diversity of situations that can affect issuers, who operate in different economic sectors and face contingencies of different magnitude and impact. This is important, so that the analysis and qualification of material events is not rigid or limited to predetermined quantitative parameters, but that there is regulatory flexibility that guarantees that not only immediate equity impacts are considered, but also contingencies, reputational risks, environmental, contractual, regulatory or governance effects that can be equally material for investors. In conclusion, the alleged “legal insecurity” invoked by the Issuer is not such, since the legal order provides clear normative guidelines with a margin of reasonable discretion. This margin does not constitute a normative
deficiency, but a mechanism that ensures that regulation is applied proportionally and appropriately to the diversity of events faced by issuers.
C. ON ALLEGED NON-OBSERVANCE OF PRINCIPLES OF ADMINISTRATIVE LAW
PRINCIPLE OF TYPICITY OR TAXATIVENESS
The Issuer states, among others, the following:

PERU Ministry of Economy and Finance
SMV
Securities Market
Superintendency
"Decade of Equal Opportunities for Women and Men" "Year of recovery and consolidation of the Peruvian economy" 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 the authorship of the signature(s) can be verified at https://apps.firmaperu.gob.pe/web/validador.xhtml “(…) contrary to what was sustained in the Sanctioning Resolution, in the present case the Principle of Typicity is not fulfilled, since the conduct attributed to our company does not correspond to the normative assumption of the infraction that is attributed to us and for which we have been sanctioned. (...) In the case of Infraction 1, given the complexity of the event, it was not possible to determine —even at the moment of communication—that the Spill had the capacity to affect the sustainability of THE ISSUER, as required by the assumption contained in paragraph 35 of Annex 1 of the Regulation of Material Events, nor that it then had the capacity of significant influence required to qualify as a material event. Nevertheless, THE ISSUER did not object that such communication was sent as a material event, as requested by the SMV. (...) Such resolution is limited to affirming that the Principle in mention is fulfilled because there is a prior typification, clearly drafted. Notwithstanding, it is not in dispute, but to sustain, and sanction, based on considering that our conduct falls within the scope of application of such typification. (...) As for Infraction 2 and Infraction 3, (...) The Sanctioning Resolution omits explaining how, the start of the procedures sanctioning referred to can significantly affect a decision of investment of a reasonable investor. The only thing they mention is an allusion to subsequent facts, which could not be known at the start of said procedures.” Regarding this, in letter C) of consideration 31 of the Impugned Resolution, the SASCM pronounced itself stating the following: “Regarding the principle of typicity, regulated in paragraph 46 of article 246 of the TUO of the LPAG, it is necessary to indicate that from the review of the infringing types contained in the Sanctions Regulation, it is evident that there is express law describing the essential elements of each of the infringing conducts, therefore what is expressed by the Issuer lacks support, since no analogies or extensive interpretations are being made on the infringing types attributed.” (Underlining and emphasis added). In this sense, it must be concluded that the present PAS fully respects the principle of typicity, as the imposed sanction is supported by laws that determine in an express and taxative manner the unfulfilled obligation, the infringing conduct and its legal consequence, being the attribution formulated in accordance with the normative assumption that describes the infraction. Regarding what is alleged about infractions 1, 2 and 3 in relation to
typicity, the discussion raised does not reveal a violation of the principle of typicity, but rather falls within the substantive analysis regarding whether the attributed facts constitute material events in accordance with the corresponding Regulation.

Regarding this matter, it is necessary to indicate that the accreditation of whether the behaviors attributed in Infractions 1, 2, and 3 qualify as material facts has already been evaluated in the specific analysis of each of them in this Resolution.

PRINCIPIO PRO HOMINE
The Issuer states, among others, the following:
"According to this principle, within the framework of a sanctioning procedure, when there is doubt regarding the way in which a certain legal provision must be applied, The Administration must always opt for the interpretation that is most favorable to the citizen. (…) In effect, with respect to Infraction 1, there was no negligence or intention to hide a fact that, moreover, was public knowledge. What happened was that, according to the ex ante analysis required by the regulations, it was not possible to determine—with the information available at that time—whether the event had the capacity to affect the sustainability of the company, or to influence significantly the decision of a reasonable investor, in such a way that it would justify its communication as a material fact.

On the other hand, regarding Infractions 2 and 3, we reiterate our request that the facts involved do not qualify as material facts, as was expressly stated at the time of our communication. It is not reasonable to expect that each situation linked to the Spill be reported through this channel, as this would imply disseminating inaccurate information and contravening the duty of diligence that governs the dissemination of relevant information.

(…)
Consequently, we believe that, in accordance with the pro homine principle, it is not valid for the Administration to impose a sanction that does not fit neither the circumstances of the case nor the conduct deployed by our company."

Regarding this matter, in subsection C) of consideration 31 of the Challenged Resolution, the SASCM pronounced itself stating the following: "With respect to the application of the pro homine principle, it is necessary to indicate that this principle is not applicable because the imputed infractions have been duly proven, they protect a public interest and there is no ambiguity in the norm that allows a more favorable interpretation for the Issuer, since the objective of the norm is to guarantee transparency and market security, and not to favor individually anyone who fails to meet an obligation."

In that sense, it is concluded that the pro homine principle is not applicable to the present case, given that there is no doubt about the content of the norm that typifies the infraction, but rather the issue raised is the accreditation of whether, in the concrete facts, the communication as a material fact and its consequent sanction corresponded, an aspect that has already been addressed in the analysis of each infraction.

PRINCIPIO DE PRESUNCIÓN DE LICITUD
The Issuer states, among others, the following:
"In the case under discussion, it is evident that the behavior attributed to our company—consisting in the alleged failure to reveal promptly material facts—has not been verified, nor is there any basis supporting the charges formulated. In effect, with respect to Infraction 1, even at the time the communication was made, it was not possible to determine that it was a material fact, given the complexity of the circumstances surrounding the event. On the other hand, regarding Infraction 2 and Infraction 3, the information involved does not meet the characteristics of material facts in accordance with the applicable regulations (i.e., capacity to significantly influence the investment decision of a reasonable investor), and it was communicated through this channel only in attention to an express request from the SMV, which demanded using said mechanism. The first instance has not presented any justification, based on information available at the time the facts occurred, that justifies the initiation of the sanctioning procedures in question as material facts. (…) Finally, in the hypothetical case that it is considered that there are elements supporting the infractions, we trust that the solidity of the arguments backing our position will be recognized, and that, in application of the Principle of Presumption of Lawfulness, preference will be given to the citizen in a scenario of doubt, dismissing the charges formulated."

Regarding this matter, in subsection C) of consideration 31 of the Challenged Resolution, the SASCM pronounced itself stating the following: "With respect to the principle of presumption of lawfulness contained in numeral 9 of article 230 of the TUO of the LPAG, which establishes that administrative entities, such as the SMV, must presume that citizens have acted in compliance with their duties unless there is evidence to the contrary. In the present case, from the review of the SMV's control systems, the conduct constitutive of the infraction has been accredited, thus overturning the presumption of lawfulness of the Issuer, in strict compliance with the other principles of administrative sanctioning power referred to in article 248 of the TUO of the LPAG."

Consequently, having verified the non-compliance and overturned the presumption of lawfulness invoked by the citizen, it corresponds to confirm in full what resolved by the SASCM, ratifying that the behaviors attributed to the Issuer constitute an administrative infraction.

PRINCIPIO DE VERDAD MATERIAL Y PRINCIPIO DE CAUSALIDAD The Issuer states, among others, the following:
"(…)

PERU Ministry of Economy and Finance
SMV
Securities Market
Superintendence
"Decade of Equal Opportunities for Women and Men" "Year of recovery and consolidation of the Peruvian economy" 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 the authorship of the signature(s) can be verified at https://apps.firmaperu.gob.pe/web/validador.xhtml It is clear that the elements configuring a material fact are not verified in this case, nor were they present at the time of the communication. Therefore, we request the SMV to refrain from imposing a sanction that would lack purpose, generating an unjustified detriment to our company, contrary to the legal order and alien to the conduct that THE ISSUER has demonstrated in fulfilling its information obligations, as evidenced by the fact of not having previous sanctions for the analyzed facts. Finally, we request that our company not be sanctioned for facts—such as the Spill—which we consider were caused by third parties, and which do not justify the inapplicability of the invoked principles, which establish that no sanction should be imposed for a non-existent non-compliance with the duties of information revelation. In effect, in the present case, non-compliance with the duty to inform material facts based on an ex ante analysis is not verified, since said analysis was indeed carried out, and the conclusion reached was that, based on the information available at that time, the submission of material facts did not correspond. The guide for this was obtained from the Material Facts Regulation itself, which in its Annex 1 states that events like the Spill must be reported if they could affect the sustainability of the company (numeral 35), in the case of Infraction 1; and in the cases of patrimonial damage considered material facts (numeral 16) with regard to Infraction 2 and Infraction 3. (…)"

Regarding this matter, in subsection C) of consideration 31 of the Challenged Resolution, the SASCM pronounced itself stating the following: "With respect to the principle of material truth, it has been fulfilled to fully verify the facts subject to evaluation in the present PAS, which includes the circumstances of the commission of the infraction and the evaluation of the information referenced by the Issuer in its defenses, that is, the non-compliance has been verified with the legal deadline established in the regulations of the matter, consequently, one cannot presume a situation contrary to this verified fact," arguments that are ratified.

Consequently, the Issuer's argument that material facts were not configured or that the ex ante analysis justified the omission in communication is not acceptable, since, as has been accredited in the procedure, the information linked to infractions 1, 2, and 3 did possess materiality to be qualified as a material fact in accordance with the applicable regulations, and its communication was carried out outside the legally established deadline. To that extent, having objectively verified the regulatory non-compliance, it corresponds to dismiss the defenses presented by the Issuer, confirming that the imputed conduct constitutes an administrative infraction in accordance with what resolved by the SASCM in the Challenged Resolution.

PRINCIPIO DE RAZONABILIDAD
The Issuer states, among others, the following:
"(…)

PERU Ministry of Economy and Finance
SMV
Securities Market
Superintendence
"Decade of Equal Opportunities for Women and Men" "Year of recovery and consolidation of the Peruvian economy" 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 the authorship of the signature(s) can be verified at https://apps.firmaperu.gob.pe/web/validador.xhtml According to the transcribed norm, this proportionality between the infraction committed and the reaction that the Public Administration must apply as a sanction is exercised in accordance with the following appreciation criteria, whose application to the present case we analyze:
a) The illicit benefit resulting from the commission of the infraction: There has been no economic benefit from these actions for the Issuer, as acknowledged by the Sanctioning Resolution. On the contrary, our company has been harmed by the initiation of the present sanctioning procedure. b) The probability of detection of the infraction: The probability of detection of the alleged infractions is high, as acknowledged by the Sanctioning Resolution. c) The gravity of the damage to the public interest and/or protected legal good: There is no damage to the public interest or protected legal good since the Issuer has not incurred in the infractions attributed to it. On the other hand, as confirmed by the Sanctioning Resolution, no damage to third parties has been verified. d) The economic harm caused: The evidence shows that there is no economic harm to any investor or to the market, as acknowledged by the Sanctioning Resolution. e) Recidivism for the commission of the same infraction: The Issuer presents no recidivism, as acknowledged by the Sanctioning Resolution. f) The circumstances of the commission of the infraction: The facts occurred in circumstances unrelated to the will of RELAPASAA, which merely limited itself to complying with what the Regulation ordered it to perform, upon receiving an information request from the SMV. In the case of Infraction 1, we find ourselves in extremely complex circumstances that did not allow defining whether we were facing a material fact. In the case of Infractions 2 and 3, we are not facing material facts; we are facing the initiation of sanctioning procedures whose outcome is impossible to foresee, let alone quantify. Therefore, it is not possible for the company to classify them as material facts. g) The existence or non-existence of intent in the infringer's conduct: It is clear that there was no dolus or intention in our company to fail to comply with its information submission obligations, as acknowledged by the Sanctioning Resolution."

In light of the above, it is evident that it does not correspond to sanction RELAPASAA.
The SMV should have assessed the imputed behaviors from the prism of reasonableness, that is, (i) choosing and interpreting the applicable norms to each case, (ii) developing the concrete elements for each charge by valuing the Issuer's conduct, and, (iii) if the need to confirm the sanction is established, adopt the most appropriate measure and with the least possible impact on rights, in this case, those of the Issuer."

Consequently, it becomes evident that the determination of the sanction has been carried out based on objective criteria, which guarantees proportionality and reasonableness in its application. Even, in attention to the Principle of Favorable Retroactivity collected in numeral 5 of article 248 of the TUO of the LPAG, the SASCM applied the sanctioning regime most beneficial to the citizen, which reaffirms that the calculation of the fine has been carried out correctly, transparently, and in accordance with the law. Therefore, it corresponds to confirm in full what resolved in the Challenged Resolution.

That, from what evaluated in the preceding considerations, it is concluded that the arguments presented by the Issuer in its reconsideration appeal do not justify revoking or varying what resolved in the Challenged Resolution, so its reconsideration appeal must be declared unfounded;
Being in accordance with the provisions of numerals 14, 22, and 36 of
article 43 of the Regulations on Organization and Functions of the Securities Market Superintendence, approved by Supreme Decree No. 216-2011-EF;
RESOLVES:
Article 1st.- Declare UNFOUNDED the reconsideration appeal filed by REFINERIA LA PAMPILLA S.A.A. against the Adjunct Superintendent Resolution SMV No. 042-2025-SMV/11 of July 18, 2025.
Article 2nd.- Confirm the Adjunct Superintendent Resolution SMV No. 042-2025-SMV/11 of July 18, 2025, which sanctions REFINERIA LA PAMPILLA S.A.A. with a total fine of 6 UIT equivalent to S/ 27,600.00 (Twenty-Seven Thousand Six Hundred and 00/100 Soles), for having incurred in three (3) minor infractions, typified in clause 3, numeral 3.1 of Annex I of the Sanctions Regulation, approved by SMV Resolution No. 035-2018-SMV/01, for the late submission of the following material facts: i) the oil spill at the installations of Multiboyas Terminal No. 2 occurring on January 15, 2022, ii) the initiation of the administrative sanctioning procedure by the Evaluation and Environmental Inspection Body - OEFA against the Issuer for failing to comply with the preventive measure to identify the zones affected by the displacement of the hydrocarbon which was notified on January 27, 2022, and iii) the initiation of the administrative sanctioning procedure by OEFA against the Issuer for failing to comply with the preventive measures referred to carrying out cleaning, containment, and recovery actions of the floating hydrocarbon in the sea of Ventanilla, which was notified on February 08, 2022.
Article 3rd.- Consider the administrative route exhausted.
Article 4th.- Transcribe this Resolution to REFINERIA LA PAMPILLA S.A.A.
Register, communicate, and publish.
Carlos Rivero Zevallos
Adjunct Superintendent
Adjunct Superintendence of Market Conduct Supervision

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