Circular No. 194-2025 — SMV — PE

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" Paseo de la Republica Avenue 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 authorship San Isidro, April 1, 2025 CIRCULAR No. 194-2025-SMV/11.1 Gentlemen Issuers of National Securities of the Main Market Risk Rating Companies Present:- Ref.: File No. 2025013924 I address you regarding the obligation of issuers of securities registered in the Public Registry of the Securities Market — RPMV — as well as legal entities registered in said registry (hereinafter, Obligated Entities), to submit Reports on their Economic Group, under the formats established by the Securities Market Superintendence – SMV, in accordance with what is provided in article 8 of the Regulation on Indirect Ownership, Linkage and Economic Groups, approved by SMV Resolution No. 019-2015-SMV/01 and its modifying norms (hereinafter, Economic Groups Regulation).

Regarding this, you are reminded that, in accordance with what is provided in article 9 of the Economic Groups Regulation, in the event that any change occurs in the reported information on the economic group, the information must be updated and submitted at the same time and jointly with the Annual Report of the Obligated Entities, unless the change qualifies as a material event, in which case, without prejudice to the respective communication, the Obligated Entity must update the information within fifteen (15) calendar days following. Likewise, in the event that the Obligated Entity does not belong to an economic group, it must present a declaration to that effect.

Likewise, for orientative purposes, an ANNEX containing general guidelines for the submission of information on the economic group, as well as a USER GUIDE for the submission of the Report on Economic Groups, is attached to this circular; documents that must be taken into account for compliance with their information obligations contained in the Economic Groups Regulation.

In the event that, as of the date of receipt of this circular, your represented entity has complied with updating the economic group information, or with presenting the declaration of not belonging to an economic group, please disregard the previously indicated instructions.

Finally, it should be noted that this circular does not require a response from your represented entity; as well as that it has a preventive and

PERU Ministry of Economy and Finance

Without further particulars, I remain at your disposal.
Sincerely,
Alix Godos
General Superintendent
General Superintendent of Conduct Supervision

PERU Ministry of Economy and Finance

ANNEX
General Guidelines
Submission of information on economic group

Economic Group Report: Formats
The Report must adhere to the content established in the Information Formats on Economic Group, approved by Superintendent Resolution No. 083-2016-SMV/02.
If the economic group has two or more Obligated Entities, the Economic Group Report must be presented by the one that has been designated for such effect, without prejudice to the responsibility corresponding to each entity. In the Economic Group Report, each of the natural persons who ultimately exercise control ─considering for this purpose, the definition of "control", as well as the criteria and presumptions of control established in article 6 of the Economic Groups Regulation─ over the group must be identified, in a complete manner. The economic group diagram is a graphical representation of the main entities that make up the economic group, indicating the percentage of participation in each of them, and the position of the Obligated Entity(ies) within the economic group. The amounts of the total value of assets and equity of each entity that makes up the economic group must refer to the fiscal year immediately preceding the date of submission of the Report, indicating the amount and currency. In cases where the legal entity does not belong to an economic group, it must present a declaration to this effect (Route in MVNet: General Requests // Type of information: Sworn Declaration Economic Group).
Information regimes on economic group
The Economic Groups Regulation establishes the following regimes for submitting the Economic Group Report:

2.1. General Regime1:
Applies to the Obligated Entity that is part of an economic group.
What must the Economic Group Report include in the General Regime?
The report must include ALL entities that are part of the economic group and the respective diagram.
1 Legal basis: Article 8, second paragraph, of the Economic Groups Regulation.

PERU Ministry of Economy and Finance

2.2. Simplified Regime2:
Applies when the Obligated Entity, or another legal entity of its economic group, has securities registered in any of the markets indicated below:
Source: Section 1 of Annex No. 15 of the Regulation on Registration and Exclusion of Securities in the Public Registry of the Securities Market and in the Stock Exchange Wheel, approved by SMV Resolution No. 031-2012-SMV/01 and its modifications. What must the Economic Group Report include in the Simplified Regime? The report must include:
(i) the legal entities of its economic group that exercise control, direct or indirect, in a straight line of ownership; (ii) the legal entities that have headquarters or representation in the country; (iii) the foreign legal entities with which the Obligated Entity has material commercial and/or financial relationship according to the definition of materiality in IFRS; (iv) the web link of the foreign regulator that allows access to public information on its economic group reported by the Obligated Entity or the legal entity member of its economic group; and, (v) the group diagram. This regime also applies to economic groups that are controlled by the Peruvian State or another foreign State that has a 2 Legal basis: Article 8, fifth, sixth and seventh paragraphs, of the Economic Groups Regulation.

PERU Ministry of Economy and Finance

2.3. SBS Regime3:
Applies to the Obligated Entity —issuer— with securities registered in the RPMV and which is also an entity authorized by the Superintendence of Banks, Insurance and Private Pension Fund Administrators — SBS, to which it reports information on its economic group. What must the Economic Group Report include in the SBS Regime? The report must include:
(i) The reports referred to in article 15 of the Special Norms on Linkage and Economic Group, approved by SBS Resolution No. 5780-2015 or the norm that replaces them; (ii) The list of natural persons who exercise final control over the economic group; and, (iii) The group diagram. The Obligated Entity —issuer— may modify the regime of the chosen report (General Regime or SBS Regime) on each occasion it must update its information.

Timing for submission of the Report
When must the Economic Group Report be submitted and/or updated?

Periodically: At the same time and together with the Annual Report of the Obligated Entity.
Occasionally: Within fifteen (15) calendar days following the material event that has determined the change in the economic group information.
Any update of the Report must be carried out considering the content of the formats approved by the SMV4.
The Obligated Entity that submits its Economic Group Report under the SBS Regime must send to the SMV any update of the information, at the same time that such information is sent to the SBS5. 3 Legal basis: Fourth Final Complementary Provision of the Economic Groups Regulation. 4 See paragraph 1 of these Guidelines (Article 8 of the Economic Groups Regulation). 5 See paragraph 2.3 of these Guidelines.

Lineage: No known changes