SBS Resolution No. 03444-2025 Approves the Operating Procedure for the Extraordinary and Voluntary Withdrawal of Funds in the Private Pension System, Established under Law No. 32445

Los Laureles Nº 214 - Lima 27 - Perú Telf. : (511)6309000 Lima, September 25, 2025 Resolución S.B.S. No. 03444-2025 The Superintendent of Banking, Insurance and Private Pension Fund Administrators CONSIDERING: That, Law No. 32445, published in the Official Gazette “El Peruano” on September 20, 2025, authorizes the extraordinary and voluntary withdrawal of funds by affiliates to the Private Pension System up to four (4) Tax Unitary Values (UIT) and establishes other provisions; That, Article 2 of the aforementioned Law No. 32445 establishes that affiliates may submit their fund withdrawal requests in physical or virtual form, within ninety (90) calendar days following the regulation's effective date; That, for its part, the First Complementary Final Provision of said Law establishes that the Superintendencia de Banca, Seguros y Administradoras Privadas de Fondos de Pensiones (SBS) determines by regulation the operating procedure to carry out the withdrawal, within a period not exceeding thirty (30) calendar days from the law's effective date, under the responsibility of its head; That, consequently, it is necessary to establish the corresponding operating procedure, with the aim that affiliates may submit their withdrawal requests to Private Pension Fund Administrators (AFP) within the deadlines set forth in Law No. 32445, to which end they must establish the most suitable channels for receiving and processing withdrawal requests, guaranteeing information security for affiliates, as well as optimal conditions for use and full compliance with the objective of the Private Administration of Pension Funds System, referenced in Article 1° of the Single Text of the Law on the Private Administration of Pension Funds, approved by Supreme Decree No. 054-97-EF, applying the principles of speed and efficiency; and considering provisions on information security and cybersecurity management contained in applicable regulations; That, additionally, it is necessary to modify the Accounting Manual for Managed Portfolios approved by SBS Resolution No. 435-2005 and its amendments, to align it with the aforementioned provisions; Having obtained the approval of the Assistant Superintendencies for Private Pension Fund Administrators, Regulation and Legal Affairs, and Market Conduct and Financial Inclusion; and,

Los Laureles Nº 214 – Lima 27 – Perú Telf.: (511) 6309000 2/5 In exercise of the powers conferred by numeral 9 of Article 349° of the General Law of the Financial System and Insurance System and Organization of the Superintendency of Banking and Insurance, Law No. 26702 and its amendments (General Law), and numeral d) of Article 57° of the Single Text of the Law on the Private Administration of Pension Funds, approved by Supreme Decree No. 054-97-EF and based on the Thirty-second Final and Complementary Provision of the General Law; RESOLVES: Article One. - Approve the Operating Procedure for the extraordinary and voluntary withdrawal of funds in the Private Pension System, established under Law No. 32445, according to the following text: “OPERATING PROCEDURE FOR THE EXTRAORDINARY AND VOLUNTARY WITHDRAWAL OF FUNDS IN THE PRIVATE PENSION SYSTEM ESTABLISHED BY LAW NO. 32445 Article 1. - Scope The operating procedure (OP) applies to Private Pension Fund Administrators (AFP) and sets forth the corresponding rules to comply with Law No. 32445, which establishes the extraordinary and voluntary withdrawal of accumulated pension funds in their individual capitalization accounts by affiliates to the Private Administration of Pension Funds System (SPP), up to four (4) tax unitary values. Article 2.- Definitions For this Operating Procedure, the following definitions apply: a) Affiliate: one incorporated into the SPP with active affiliate status. b) AFP: Private Pension Fund Administrators. c) Required capital: The amount referred to in literal h) of Article 2° of Title VII of the Compendium of Regulatory Superintendence Norms for the SPP, approved by Resolution 232-98-EF/SAFP. d) CIC: Individual Capitalization Account for Mandatory Contributions. e) CUSPP: Unique Identification Code of the Private Pension System. f) Law: Law No. 32445. g) OP: Operating Procedure. h) SISCO: Collective disability and survivorship insurance, provided by insurance companies awarded the tender for administering disability, survivorship, and funeral expense risks in the SPP. i) SPP: Private Administration of Pension Funds System. j) Superintendency: Superintendency of Banking, Insurance, and Private Pension Fund Administrators. k) UIT: Tax Unitary Value. l) Quota value: Unit of measurement expressing the value of pension funds. Article 3.- Extraordinary and voluntary withdrawal in accordance with Article 2° of Law No. 32445 Deadlines to request withdrawal and withdraw the withdrawal request 3.1 An affiliate who decides to withdraw their funds under the scope of the Law must submit their extraordinary and voluntary withdrawal request for their CIC indicating the amount to be withdrawn, within a maximum period of ninety (90) calendar days, counted from the effective date of the Superintendency resolution approving the OP, based on the mechanisms established in numeral 3.3. 3.2 If an affiliate wishes to withdraw their CIC fund withdrawal request, they may notify the AFP only once, up to ten (10) calendar days before the date any of the disbursements is scheduled, revoking payment of future scheduled disbursements. For this purpose, the affiliate must submit their request through the channels and platforms set forth in numeral 3.3 of this OP. The AFP must respond to the request through a medium that preserves evidence thereof. Channels and platforms for service and information 3.3 The AFP must establish and disseminate mechanisms to guarantee the availability and proper functioning of service channels for withdrawal and/or withdrawal requests from its affiliates, as provided in Article 2° of the Law. For platforms supporting request registration, these must meet minimum standards allowing correct completion and submission in terms of time and access, as well as cybersecurity and information preservation mechanisms applicable under regulations. 3.4 The AFP must implement the most suitable information mechanisms for the affiliate, ensuring timeliness and access, so that the extraordinary and voluntary withdrawal procedure is carried out within established deadlines. The AFP must provide guidance to the affiliate on the voluntary withdrawal and/or its withdrawal process across various communication channels, and optionally through those of the representing trade group. Disbursement deadlines 3.5 The AFP provides fund delivery according to the following disbursement schedule, up to completing the requested amount: 3.5.1 First disbursement of up to 1 UIT: Within a maximum period of 30 calendar days, counted from the date the request was submitted to the AFP. 3.5.2 Second disbursement of up to 1 UIT: Within a maximum period of 30 calendar days, counted from the date the first disbursement was made by the AFP. 3.5.3 Third disbursement of up to 1 UIT: Within a maximum period of 30 calendar days, counted from the date the second disbursement was made by the AFP. 3.5.4 Fourth disbursement of up to 1 UIT or the remaining requested amount: Within a maximum period of 30 calendar days, counted from the date the third disbursement was made. Withdrawal amount and payment method 3.6 The affiliate may request the extraordinary and voluntary withdrawal of funds, up to an amount of four (4) UIT, regarding the total registered in their CIC for mandatory contributions, as of the date of submitting the respective request. 3.7 The UIT value to be considered for the extraordinary withdrawal is that in effect on the date of submitting the request by the affiliate to the AFP. 3.8 The AFP is responsible for providing the suitable means to make payment effective, noting the correspondence between account ownership and the applicant's identity, oriented toward providing service coverage to affiliates who requested the extraordinary and voluntary withdrawal, potentially entering into agreements with financial system companies or others facilitating payment, based on Article 4 of the Law; guaranteeing that payment corresponds to the amount requested by the affiliate. Judicial or conventional withholding 3.9 The AFP is responsible for carrying out judicial or conventional withholding, only regarding pronouncements derived from alimony debts, up to a maximum of thirty percent (30%) of each disbursement amount, as provided by the Law. Article 4.- Affiliates residing abroad or with physical inability Affiliates residing abroad or physically unable may submit their extraordinary and voluntary withdrawal request or withdrawal through the channels and platforms enabled for this purpose, with the AFP responsible for establishing protocols allowing them to identify the requesting owner. Such protocols must be disseminated by the AFP on its website and other dissemination media as deemed necessary, in accordance with numerals 3.3 and 3.4 of Article 3 of this OP. Article 5.- Coverage of pension insurance against disability or survivorship events In the event that, following the extraordinary and voluntary withdrawal of pension funds, a disability or survivorship event covered by pension insurance occurs, insurance companies under the SISCO scope providing the additional contribution deduct the withdrawn amount, resulting from the valuation of corresponding quotas, from the required capital for purposes of disability and/or survivorship pension payments. Article 6.- Treatment of impacts on the CIC due to the extraordinary and voluntary withdrawal of pension funds Impacts on the CIC due to the collection of commissions on managed balances are subject to the principle of proportionality regarding fund composition, accounted for on the date the respective charge is made in the affiliate's CIC. Article 7.- Extraordinary and voluntary withdrawal when a balance transfer request is pending If an extraordinary and voluntary withdrawal has been requested under the scope of the Law, while a balance transfer request for mandatory contribution CIC funds is pending, the AFP must continue processing both procedures without interruption, subject to the treatment provided in the Fifty-eighth Final and Transitional Provision of Title V of the Compendium of Regulatory Superintendence Norms for the SPP, approved by Resolution No. 080-98-EF/SAFP, regarding Affiliation and Contributions. Article 8.- Extraordinary and voluntary withdrawal in cases of pure multi-affiliation For affiliates with pure multi-affiliation, the AFP holding a deactivated CUSPP due to non-corresponding affiliation must transfer contributions within three (3) business days according to current regulations. Likewise, AFPs involved in pure multi-affiliation must establish information exchange procedures regarding this group of affiliates to guarantee compliance with deadlines and maximum amounts for the extraordinary and voluntary withdrawal payment. Article 9.- Quota value to be used for disbursements The AFP must apply the quota value in effect on the date of charge in each disbursement's CIC, as provided in numerals 3.5.1 to 3.5.4 of this OP.” Article Two. - Modify Circular No. AFP-109-2010, regarding Operational Codes, to use the following operational code for recording charges to Mandatory Contribution CICs resulting from this type of request, in the “Deliveries (8_)” group:

• 8C Disposition of up to 4 UIT – Law No. 32445. Article Three. - Modify Chapter III “Catalog of Accounts” and Chapter IV “Description and Dynamics of Accounts” of the Accounting Manual for Managed Portfolios, approved by SBS Resolution No. 435-2005 and its amendments, to incorporate analytical account 20042393 “Affiliate disposition in accordance with Law No. 32445” within subaccount 2004239 “Affiliate disposition in accordance with specific laws”. Article Four. - This resolution takes effect on October 21, 2025. Registered, communicated, and published. SERGIO JAVIER ESPINOSA CHIROQUE SUPERINTENDENT OF BANKING, INSURANCE, AND AFP