Circular No. 481-2025

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" Av. Paseo de la Republica 3617 San Isidro Central: 610 - 6300 www.smv.gob.pe 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 San Isidro, November 4, 2025

CIRCULAR No. 481-2025-SMV/11.1

Gentlemen
Issuers of the General Regime
Issuers of the Alternative Securities Market
Present:-
Ref.: File No. 2025047408

I address you regarding what is established in
Article 10 of the Regulation on Primary Public Offerings and Sale of Securities,
approved by CONASEV Resolution No. 141-98-EF/94.10 and its modifying norms (hereinafter, OPP Regulation); Section Third, letter K of the Manual for the Compliance with the Requirements Applicable to Public Offerings of Securities, approved by General Management Resolution No. 211-98-EF/94.11 (hereinafter, Manual); and, in General Management Resolution No. 067-2000-EF/94.11.

In this regard, within the framework of the administrative activities of an orientative nature being carried out by the General Superintendence of Conduct Supervision – IGSC, it is appropriate to remind you, in accordance with what is established by the OPP Regulation, the following:

1. The registration of securities in the Public Registry of the Securities Market
   – RPMV is carried out by classes, identifying them by their characteristics.
2. A class is understood as the set of homogeneous securities, which have been
   issued in a single act or in successive acts.
3. Homogeneity is determined based on the nature of the securities, so that,
   according to the circumstances, they present characteristics that make them fungible, and it may be established, within said set of securities, series formed by subsets of fungible securities.
4. The series within a class may differ in accessory aspects 1.

Likewise, in accordance with the Manual and General Management Resolution No. 067-2000-EF/94.11, for the purposes of the homogeneity of the securities referred to in said Article 10 of the OPP Regulation, the following are not considered as accessory aspects: i) the issuance term, ii) the currency type, and iii) the formula for calculating the interest rate, insofar as such factors are determinants for the taking of investment decisions in the market and the corresponding evaluation and weighting of risks. Consequently, securities that are registered in the RPMV under the same class or issuance must maintain their homogeneity. Without prejudice to what is indicated

1 Such as nominal value, issuance dates, placement dates, physical delivery dates, or price fixing dates, placement procedure, among others.

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" Av. Paseo de la Republica 3617 San Isidro Central: 610 - 6300 www.smv.gob.pe 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 the present paragraph, it must be taken into account that what is established regarding the term of the issuance is not applicable to short-term instruments.

On the other hand, when the series within a securities issuance differ in aspects not considered as accessory, the registration of the securities constituting said series will be carried out as separate classes; in such a case, you must observe what is established in the Manual regarding the information prospectus 2.

In that sense, taking into account the above, you are exhorted to take the necessary measures to strictly observe the provisions of the OPP Regulation, the Manual, and General Management Resolution No. 067-2000-EF/94.11, which includes, among others, that the series of securities placed are homogeneous and fungible with each other, as well as that in the respective complementary prospectuses of the securities issuances, your represented entity establishes in a clear and precise manner, the conditions referred to the issuance term, the currency type, and the formula calculating the interest rate.

Finally, it corresponds to clarify that this Circular is issued with an orientative character and aims to reiterate to you the provisions established regarding the exposed regulations, in such a way that your represented entity complies fully with them.

Without further particulars, I remain at your disposal.
Sincerely,

Alix Godos
General Superintendent
General Superintendence of Conduct Supervision

2 "K. Criteria to determine homogeneity within a class of securities, for the purposes of what is established in Article 10 of the Regulation on Primary Public Offerings and Sale of Securities Securities, approved by CONASEV Resolution No. 141-98-EF/94.10. (…) In such a case, a common prospectus may be used; however, with the aim of safeguarding the transparency of the securities market, when relevant, the information prospectus must contain specific risk factors for each series, point out the inconveniences that may arise from the fact that holders of securities from said series meet in a single assembly having interests that may be opposed, and indicate any other aspect or implication derived from said fact. Notwithstanding the foregoing, depending on the magnitude of the differences between the series, separate prospectuses and risk classifications may be required for all or some of them."