Adjunct Superintendent Resolution SMV No. 052-2025-SMV/11 — SMV — PE

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 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. 052-2025-SMV/11
Lima, August 20, 2025

Subject: To sanction RIMAC SEGUROS Y REASEGUROS with a reprimand for having committed one (1) minor infraction, typified in item 3.1 numeral 3 of Annex I of the Sanctions Regulation

Administered: RIMAC SEGUROS Y REASEGUROS
Subject: Administrative Sanctioning Procedure of single administrative instance Main Type: Item 3.1 numeral 3 of Annex I of the Sanctions Regulation MINOR INFRACTION File No.: 2025002481

The Adjunct Superintendent of Market Conduct Supervision

SEEN:

The administrative file No. 2025002481, containing the administrative sanctioning procedure (hereinafter, PAS) initiated by the General Superintendent of Conduct Compliance of the Securities Market Superintendency - SMV (hereinafter, IGCC), against RIMAC SEGUROS Y REASEGUROS (hereinafter, the Issuer); as well as Report No. 927-2025-SMV/11.2 (hereinafter, the Report), issued by said IGCC;

CONSIDERING:

I. FUNCTION AND COMPETENCE OF THE SASCM

That, the IGCC –the instructing body of the PAS referred to in this case– has brought to the knowledge of the Adjunct Superintendency of Market Conduct Supervision of the SMV (hereinafter, SASCM), the PAS contained in administrative file No. 2025002481 with the aim that it issues a decision as the sanctioning body of single instance, according to the type of infraction evaluated. In this way, the SASCM assumes competence in observance of the exercise of the supervision function and the sanctioning power of the SMV established

PERU Ministry of Economy and Finance

through the Unified Concordant Text of its Organic Law, Decree Law No. 26126 (hereinafter, LOSMV), and the Unified Text of the Securities Market Law, Legislative Decree No. 861, approved by Supreme Decree No. 020-2023-EF-11 (hereinafter, TUO of the LMV); as well as by what is provided in the Sanctions Regulation, approved by SMV Resolution No. 035-2018-SMV/01 (hereinafter, Sanctions Regulation); and, in articles 42 and 43 of the Organization and Functions Regulation of the SMV, approved by Supreme Decree No. 216-2011-EF (hereinafter, ROF-SMV), in the sense that it is a specific function of the SASCM, to impose sanctions in single administrative instance for the commission of infractions whose compliance control corresponds to the referred Adjunct Superintendency. 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, DEFENSES AND ALLEGATIONS

2.1 Facts

That, it was evaluated whether the Issuer complied with the obligation to communicate material facts in a timely manner;

2.2 Charge

That, as a result of said evaluation, through Letter No. 542-2025-SMV/11.2 of February 18, 2025 (hereinafter, the Charge Letter), the IGCC formulated the charge for late communication of the material fact against the Issuer, for the facts detailed below:

(i) Through a material fact of September 8, 2023, the Issuer communicated the registration and delivery date of the common shares resulting from the capital increase by capitalization of profits approved in the General Shareholders' Meeting (GSM) held on March 28, 2023, which was registered in the Public Registries on August 18, 2023, setting the registration date as September 14, 2023 and the delivery date as October 5, 2023.

(ii) Subsequently, through a material fact of September 11, 2023, the Issuer corrected the registration date, establishing a new registration date for September 29, 2023. Likewise, through a new material fact of September 11, 2023, prior to a previous communication from the Lima Stock Exchange - BVL, it informed that the registration date communicated on September 8, 2023 did not comply with having a minimum advance of twelve (12) business days to its occurrence of the GSM agreement according to the applicable regulation, indicating the following: "(...) we inform you that we have sent a material fact correcting the material fact reported on Friday, September 8, 2023, in which, involuntarily, a material error was committed in identifying the Registration Date referred to in the latter communication, the correct date being September 29, 2023, in line with what is provided in the applicable regulation." (Underline added).

(iii) In view of the above, it is observed that through a material fact of September 11, 2023, the Issuer corrected the registration date communicated to the SMV, which should have been corrected on the same day the said registration date was communicated (September 8, 2023), as it was a material error as reported. In consequence, it is considered that the material fact of September 11, 2023, is late.

That, in that sense, through the Charge Letter, the commission of one (1) minor infraction typified in item 3.1 of numeral 3 of Annex I of the Sanctions Regulation was imputed to the Issuer; and, a deadline of ten (10) business days was granted to present their corresponding defenses;

2.3 Defenses and Allegations

That, through a document presented on February 25, 2025, the Issuer requested an extension of the deadline to present defenses for a period equal to that granted in the Charge Letters;
That, in attention to the deadline extension request made by the Issuer, through Letter No. 1135-2025-SMV/11.2 of March 3, 2025, this Office granted a ten (10) business day extension in order to present their defenses;
That, through a document presented on March 17, 2025, the Issuer within the extended deadline granted to present defenses, recognized responsibility for the imputed infraction and developed principles and criteria for the calculation of the applicable sanction, which will be evaluated within the corresponding section;
That, the Unified Text of the General Administrative Procedure Law, approved by Supreme Decree No. 004-2019-JUS (hereinafter, TUO of the LPAG) contains common rules for the actions of the State's administrative function and regulates all administrative procedures developed in the entities, including special procedures. Likewise, numeral 3) of article 248 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 severity of the damage to the public interest and/or protected legal good, (d) The economic harm caused, (e) Recidivism, for the commission of the same infraction within a period of one (1) year from when the resolution sanctioning the first infraction became final, (f) The circumstances of the commission of the infraction; and, (g) The existence or not of intent in the conduct of the infringer;
That, the charge formulated, the recognition of responsibility for the infraction formulated by the Issuer and the criteria regarding the graduation of the sanction have been the subject of evaluation in the Report, which has been brought to the knowledge of the SASCM;
That, in observance of what is provided by numeral 5 of article 255 of the TUO of the LPAG, through Letter No. 4037-2025-SMV/11 of July 30, 2025, the Report was sent to the Issuer, so that they can send their allegations within a deadline of five (5) business days of notification;
That, in attention to this, through a document of August 8, 2025, the Issuer presented a document manifesting conformity with the sanction proposal contained in the Report;

III. QUESTIONS TO DETERMINE

PERU Ministry of Economy and Finance

That, in the present PAS it corresponds to determine the following:

(i) Whether the Issuer incurred or not in the infraction indicated in the Charge Letter and Report.

(ii) Whether it corresponds or not to sanction the Issuer.

IV. ANALYSIS

4.1 Applicable Regulation

That, article 30 of the TUO of the LMV establishes the following:

"Article 30.- Material Facts.- The registration of a certain security or issuance program entails for its issuer the obligation to inform the SMV and, if applicable, to the respective stock exchange or entity responsible for conducting the centralized trading mechanism, of material facts, including ongoing negotiations, about itself, the security and the offer made of it, as well as to disclose such facts in a truthful, sufficient and timely manner.

The information must be provided to said institutions and disclosed as soon as the fact occurs or the issuer takes knowledge of it, as the case may be. The importance of a fact is measured by the influence it may exercise on a sensible investor to modify their decision to invest or not in the security";

That, in the same sense, numeral 9.1 of article 9 of the Regulation on Material Facts and Inside Information, approved by SMV Resolution No. 005-2014-SMV/01 (hereinafter, Regulation on Material Facts), establishes the following:

"Article 9.- Opportunity to inform material facts

9.1. The Issuer must inform its material fact as soon as such fact occurs or the Issuer takes knowledge of it, and in no case beyond the day on which it has occurred or has been known (...)

In case that the material fact occurs or that the Issuer takes knowledge of it on a non-business day, it must communicate it no later than the next business day and before the start of the trading session of the centralized trading mechanism in which its securities are listed";

That, it is worth indicating that numeral 5.1 and the last paragraph of article 5 of the Regulation on Material Facts indicate the following:

"Article 5.- Information that by its nature may qualify as a material fact

5.1. In the Annex that forms part of this Regulation, an enumerative list of facts, acts, agreements and decisions is included, which aims to facilitate the Issuer's identification, qualification and classification of the information that could qualify as a material fact

(...)

Any reference to Annex in this article shall be understood as referring to Annex 1";

That, according to numeral 14 of Annex 1 of the Regulation on Material Facts, the following may qualify as a material fact:

"14. Information relating to the distribution or application of profits of the fiscal year, indicating the amount and fiscal year to which it corresponds, and, if applicable, the dividend and/or percentage of released shares that corresponds per common and/or investment share, the number of shares benefited, as well as registration date and delivery date of any value or benefit";

That, likewise, numeral 12.3 of article 12 of the Regulation on Material Facts establishes the following:

"Article 12.- Rectification of material facts by the Issuer in exceptional circumstances

(...)

12.3. The rectification is carried out without prejudice to the responsibilities that may arise";

That, additionally, articles 5 and 7 of the Regulation on Cut-off, Registration and Delivery Date, approved by CONASEV Resolution No. 069-2006-EF/94.10, establishes the following:

"Article 5.- The registration and/or delivery dates must be informed as a material fact observing the content and deadline established in articles 4 and 7 of this regulation.

The dates and the content referred to in the previous paragraph, once informed as a material fact, must not be modified or left without effect, unless it is a material error, in which case it must be corrected on the same day through a new material fact.

(...)

"Article 7.- The issuer must inform the registration date within a period of fifteen days after the corporate agreement has occurred or, if applicable, after the corresponding registration in the Public Registries.

Additionally, whether it is a registrable act or a non-registrable act, the registration date must be informed at least twelve days before the day determined by the issuer as the registration date. This period does not include the day of communication as a material fact nor the day established as the registration date.

(...)

That, the late presentation of material facts is typified in item 3.1 of numeral 3 of Annex I of the Sanctions Regulation, which 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 facts and, annual reports";
That, according to article 35 of the Sanctions Regulation, such infractions are sanctionable with a reprimand or a fine not less than one (1) UIT and up to twenty-five (25) UIT;

4.2 Evaluation of the Case

That, in administrative file No. 2025002481, which contains the documentation of the present PAS, it is appreciated that through Memorandum No. 4413-2023-SMV/11.1 of October 19, 2023 (File No. 2023043859), the General Superintendent of Conduct Supervision (hereinafter, IGSC) —the body of the SMV that has within its functions and powers, the supervision of compliance with the regulations applicable to companies with securities registered in the RPMV, evaluating the indications of possible infractions, and sends, for its consideration, the respective reports of indications of infractions, to the IGCC—, sent to the IGCC, the result of its evaluation, and specifically what refers to the present case;
That, it must be kept in mind that the procedures and legal forms with which the IGSC conducts its inspection and/or supervision activity and upon concluding it with a report of indications of infractions, determine that its pronouncement or opinion on a specific supervision topic—which can even contain a decision, for example, the adoption of corrective measures—, is an opinion on the merits of the matter; it must be specified that said opinion and the report of indications of infractions of the IGSC, is not binding for the IGCC, as established in the second paragraph of article 9 of the Sanctions Regulation 12 ;
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 this Resolution, two (2) other administrative bodies of the SMV, functionally independent from each other and from this Office; first the IGSC that at its time reported the indication of infraction and then the IGCC that, as a result of its evaluation, formulated the Charge Letter 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 charge, being precise to indicate that by the nature of the same, as previously stated, it will be a decision of single administrative instance;

1 In article 245 of the TUO of the LPAG it is indicated as forms or modes in which the inspection activity could conclude the following: 1) Certificate of conformity of the activity developed by the administered; 2) Recommendation of improvements or corrections of the activity developed by the administered; 3) The warning of the existence of non-compliances not susceptible of meriting the determination of administrative responsibilities; 4) The recommendation of the start of a procedure with the aim of determining the administrative responsibilities that correspond; 5) The adoption of corrective measures and 6) Other forms as established by special laws.

2 Article 9.- PRELIMINARY INQUIRIES AS A CONSEQUENCE OF SUPERVISION ACTIONS

(...)

When said bodies 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 start or not an administrative sanctioning procedure. If the case arises, the General Superintendencies of Compliance may carry out additional inspections or investigations of the reported indications. In the case of possible infractions in the scope of the Regulation of the Participatory Financing Activity and its Managing Companies, the preliminary inquiries are carried out by the General Superintendent of Investigation and Innovation, a dependency that if there are sufficient indications of possible administrative infractions will determine if it corresponds to start or not an administrative sanctioning procedure.

PERU Ministry of Economy and Finance

24. That, with respect to the defenses presented by the Issuer, it corresponds to indicate the following:

1. Recognition of responsibility for infraction

In its defenses, the Issuer states the following:

"With respect to the imputation of infraction that has been formulated against us, please consider that we recognize that it occurred. Indeed, although involuntarily, a material error was committed in communicating the date corresponding to the aforementioned registration date, and its correction could not be made on the same day, as established in article 5 of the Regulation on Cut-off, Registration and Delivery Date."

Analysis

The Issuer expressly recognizes its responsibility for the commission of the infraction referred to the late presentation of the material fact on the correction of the registration date due to material error, pursuant to letter a) of numeral 2 of article 257 of the TUO of the LPAG.

Regarding this, it corresponds to indicate that the voluntary declaration of recognition of the infraction by the Issuer is deemed as a mitigating condition of responsibility, so that when the applicable sanction is a fine, it is reduced by fifty percent (50%) if the recognition is presented within the deadline granted to present defenses, according to numeral 1 of letter a) of article 26 of the Sanctions Regulation 3 , which will be considered at the time of the determination of the sanction.

Principle Pro Homine, Principle of application of the most favorable norm and Principle of Reasonableness

With respect to these principles, in its defenses, the Issuer develops the following:

"In the present case (...) we consider that, without prejudice to the recognition of verification of the infraction imputed to us, there are grounds and reasons that support that the Administration, considering the circumstances of the case, and mainly its involuntary character, that we have adopted measures to avoid its repetition, its rapid and voluntary subsanation, and its null repercussion, abstains from sanctioning RIMAC, or that, in any case, applies a sanction of reprimand.

We consider that, in attention to the Principle stated [Principle pro homine], and without prejudice to the unfortunate error incurred, and fully recognized and corrected, there are no reasons to impose a more burdensome measure than the one stated above."

3 Article 26.- CRITERIA FOR THE GRADUATION OF THE SANCTION

(...)

a) Mitigating circumstances:

Voluntary recognition of the infraction before the initiation of the administrative sanctioning procedure or within the deadline granted to present defenses, provided that it is accompanied by the restitution of the illicit benefit or the repair of the damage caused, if applicable.

Article 26.- Mitigating factors for liability for infractions
The following constitute mitigating conditions for liability for infractions:
a) Acknowledgment of liability by the offender in an express and written manner, once the administrative sanctioning procedure has been initiated.
When the applicable sanction is a fine, it is reduced, taking into account the following:

If the acknowledgment of the infraction is submitted within the deadline granted for the submission of defenses, the amount of reduction shall be fifty percent (50%).
(…)

PERU Ministry of Economy and Finance

At the time of determining the sanction, the possibility or not of applying a reprimand to the Issuer will be evaluated, based on the fulfillment of the specific assumptions established in the regulations.
Since the infraction was committed when the Criteria applicable to the administrative sanctioning procedure for non-compliance with the regulations governing the submission of periodic or occasional information, approved by SMV Resolution No. 006-2012-SMV/01 (hereinafter, Sanctioning Criteria), were in force, at the time of determining the sanction, it will be analyzed whether the provisions of the Gradual Sanctions Regime for late submission of financial information, annual reports, and material facts, approved by SMV Resolution No. 007-2023-SMV/01 (hereinafter, Gradual Sanctions Regime), should be applied, as they are more favorable to the Issuer.
The sanctioning criteria referred to by the Issuer will be analyzed at the time of determining the sanction.

Request for abstention
In its defenses, the Issuer states the following:
“According to what is provided in the last paragraph of the aforementioned article 25 of the Sanctions Regulation, when, from the evaluation of the criteria mentioned above, the SMV finds that there is no proportionality between the sanction that should be imposed according to the type of infraction and the imputed facts, by exception and through a reasoned decision, it may impose a sanction corresponding to a classification lower than that provided.

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" Electronically signed document in 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 Finally, it is appropriate to indicate that at the time it was considered that the facts corresponding to the present case did not have little significance, a condition that must be accredited for the application of an abstention.
4. Request for reprimand
Regarding this, the Issuer states the following:
“Now, if abstention is not opted for, we request that it be considered that, according to the Special Sanctioning Criteria and the New Gradual Sanctions Regime, in the present case, the elements are present for the sanction to be imposed to be a reprimand.
Indeed, in the present case, the following elements are present, provided for in number 4.2 of the aforementioned Special Sanctioning Criteria, according to which the imposition of the aforementioned reprimand sanction would correspond in any case:
(i) The affectation to transparency in the market has been non-existent or, at most, minimal (…); (ii) The infraction committed has not caused concrete harm to investors or associates (…); (iii) RIMAC does not have antecedents or, if it does, they are infractions classified as minor offenses imposed in the four years prior to the commission of the infraction being evaluated; (iv) RIMAC has not obtained a benefit from its conduct; and (v) RIMAC has not acted with intent in incurring the infraction. Likewise, the criteria established in number 6.1 of the New Gradual Sanctions Regime are met, according to which the imposition of the aforementioned reprimand sanction would also correspond:
(a) When the affectation to transparency in the market is minimal. This criterion is verified in the present case, as we have explained; (b) The infraction committed has not caused concrete harm to investors or associates. As can be verified, no harm has been generated to investors; (c) The offending subject does not have antecedents or, if it does, they are sanctions corresponding to minor infractions imposed by the SMV that had become final in the four (4) years prior to the commission of the infraction being evaluated. This criterion is met, as we have explained; (d) The offending subject is not a recidivist. This criterion is also met, as RIMAC is not a recidivist; (e) The offender has not obtained benefits from his administrative infraction. It is clear that RIMAC has not obtained any benefit; and, (f) It has not been proven that the offender acted with intent in the commission of the infraction. It is clear that RIMAC did not act with intent, having presented a human error, which was corrected, having adopted the respective internal measures to prevent it from occurring again.” Analysis As previously noted, at the time of determining the sanction, the possibility or not of applying a reprimand to the Issuer will be evaluated, based on the fulfillment of the specific assumptions established in the regulations.
25. That, therefore, it has been proven that the conduct of the Issuer regarding the late communication of the material fact is reproachable in that it did not act with the required diligence, thereby affecting the transparency of the securities market;
V. DETERMINATION OF THE SANCTION
26. That, the non-compliance referred to regarding the late submission of material facts is classified in paragraph 3.1 of number 3 of Annex I of the Sanctions Regulation, which states that it constitutes a minor infraction: “To submit outside the established deadline, or to do so incompletely, or, without observing the technical specifications approved by the SMV or without communicating the approval by the corresponding corporate body, to the SMV, to the Stock Exchange, to the entity in charge of the centralized negotiation 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 facts, and annual reports.”;
27. That, according to article 35 of the Sanctions Regulation, such infraction is sanctionable with a reprimand or a fine not less than one (1) UIT and up to twenty-five (25) UIT;
28. That, for the purpose of analyzing the corresponding sanction for this type of non-compliance, what is provided in article 25 of the Sanctions Regulation must be taken into account, in such a way, it proceeds to analyze: (i) the sanctioning antecedents; (ii) 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; (iii) the circumstances of the commission of the infraction; (iv) the economic harm caused and its repercussion in the market; (v) the illicit benefit resulting from the commission of the infraction; (vi) the probability of detection of the infraction; (vii) the gravity of the damage to the public interest and/or protected legal good; and, (viii) the existence or non-existence of intent in the offender's conduct, in concordance with what is provided by number 3) of article 248 of the TUO of the LPAG and article 348 of the LMV;
29. That, in addition to the previously cited norms, for the purpose of determining the sanction, the Sanctioning Criteria, as well as the Gradual Sanctions Regime 4, will be taken into consideration;

4 Article 2 of SMV Resolution No. 007-2023-SMV/01 repealed the Criteria applicable to the administrative sanctioning procedure for non-compliance with the regulations governing the submission of periodic or occasional information, approved by SMV Resolution No. 006-2012-SMV/01. On the other hand, article 4 of SMV Resolution No. 007-2023-SMV/01 established its validity as of January 01, 2024.

PERU Ministry of Economy and Finance

PERÚ Ministry of Economy and Finance

SMV
Superintendencia del Mercado de Valores
“Decenio de la Igualdad de Oportunidades para Mujeres y Hombres” "Año de la recuperación y consolidación de la economía peruana" 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 of the Sanction Criteria and item 6.1 of article 6 of the Gradual Regime, it is observed that this latter provision has established an additional condition for the application of the reprimand sanction (that the infringer is not a recidivist). In that sense, the subsequent norm is not more favorable, so item (ii) of item 4.2 of the Sanction Criteria must be applied, in order to determine if the reprimand sanction proceeds;
42. That, in that sense, in the present PAS, it can be
affirmed the following: (i) the impact on market transparency was minimal, since although there was a delay in the presentation of the important fact, this was four (4) calendar days; (ii) the committed infringement has not caused concrete harm to investors; (iii) The Issuer has one prior record of infringement, but this refers to an infringement typed as minor; (iv) it has not been evidenced that the Issuer has obtained a benefit from their illegal conduct; and (v) it has not been accredited that the Issuer acted with intent in the commission of the infringement;
43. That, according to the evaluation of the Sanction Criteria
previously carried out and the analysis carried out by this Adjunct Superintendency, it corresponds to impose on the Issuer a reprimand sanction for the late presentation of the important fact regarding the correction of the registration date due to material error; ON THE RECOGNITION OF RESPONSIBILITY
44. That, as previously stated, the
Issuer manifested in its defenses that it recognized its responsibility for the commission of the infringement subject of this report. According to the Sanction Criteria indicated, a reprimand sanction has been determined, therefore, since no fine sanction is determined, it lacks object to apply the fifty percent (50%) discount established in item 1 of literal a) of article 26 of the Sanctions Regulation, which regulates the recognition as a mitigating factor for sanction.
45. That, therefore, it corresponds to impose on the Issuer
a reprimand sanction for the non-compliance subject of the present PAS, and; Being subject to what is provided in item 14 of article 43 of the Organization and Functions Regulation of the SMV, approved by Supreme Decree No. 216-2011-EF; RESOLVES:
Article 1º.- Declare that RIMAC SEGUROS Y
REASEGUROS has incurred one (1) minor infraction, typified in item 3.1 of item 3 of Annex I of the Sanctions Regulation, approved by SMV Resolution No. 035-2018-SMV/01, by having presented late the important fact of correction of the registration date due to material error.
Article 2º.- Sanction RIMAC SEGUROS Y
REASEGUROS with one (01) reprimand, for what is provided in article 1 of this Resolution.
Article 3º.- 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 218 of the Single Text Ordered of the General Administrative Procedure Law – Law No. 27444, approved by Supreme Decree No. 004-2019-JUS, within the term of fifteen (15) business days, counted from the day following its notification.
Article 4º.- In case this Resolution is not
subject to challenge through reconsideration appeal, it must be published on the Institutional Page of the SMV in the Unique Digital Platform of the Peruvian State for Citizen Orientation (www.gob.pe/smv), in observance of what is provided by item 1 of article 7 of the Policy on publicity of normative projects, general character legal norms and other administrative acts of the SMV, approved by SMV Resolution No. 014-2014-SMV/01, and by what is provided in the last paragraph of
article 14 of the Sanctions Regulation, approved by SMV Resolution No. 035-2018-
SMV/01.
Article 5º.- Transcribe this Resolution to El
Emisor Seguros y Reaseguros.
Register, communicate and publish.
Carlos Rivero Zevallos
Adjunct Superintendent
Adjunct Superintendency of Supervision of Market Conducts

Lineage