Circular No. 74-2026-SMV/11.1: Obligation to Disclose Monthly Position in Financial Derivative Instruments

PERU Ministry of Economy and Finance

SMV
Superintendence of the Securities Market

"Decade of Equal Opportunities for Women and Men" "Year of Hope and the Strengthening of Democracy"

Av. Paseo de la República 3617 San Isidro
Central: 610-6300 www.gob.pe/smv

Electronic document digitally signed under Law N° 27269, Law on 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, February 26, 2026

CIRCULAR Nº 74-2026-SMV/11.1

To:
Issuers under the General Regime
Present.-

Ref.: File Nº 2026008873

I address you in relation to the obligations of issuers with securities registered in the Public Registry of the Securities Market – RPMV under the Superintendence of the Securities Market – SMV, among which is the obligation to disseminate important events truthfully, sufficiently, and timely, as provided by Article 27 of the Securities Market Law, Legislative Decree N°861 and its amendments, and by the Regulation on Important Events and Reserved Information, approved by SMV Resolution N° 005-2014-SMV/11.1 and its amendments (hereinafter, HI Regulation).

In this regard, within the framework of Articles 3, 4, and 5 of the HI Regulation, and considering that your company, when presenting its intermediate individual or separate financial statements as of December 31, 2025, declared that it is obliged to present information on the monthly position of its financial derivative instruments, it is necessary to remind your company of its obligation to disseminate, as an important event, the monthly position in financial derivative instruments, according to numeral 18.11 Annex 1 and Annex 2 "Monthly position in financial derivative instruments" of the HI Regulation, which states the following:

« Annex 2
Monthly position in financial derivative instruments (...)
4. The obligated issuer must submit, within ten (10) business days after the close of each month, an important event with the following details of its derivative instruments updated as of the report date:

1. Derivative Instrument.
2. Purpose.
3. Notional Amount.
4. Asset / Liability or Variable covered by the derivative.

1 "Monthly position in financial derivative instruments, in accordance with the provisions of Annex 2".

PERU Ministry of Economy and Finance

SMV
Superintendence of the Securities Market

"Decade of Equal Opportunities for Women and Men" "Year of Hope and the Strengthening of Democracy"

Av. Paseo de la República 3617 San Isidro
Central: 610-6300 www.gob.pe/smv

Electronic document digitally signed under Law N° 27269, Law on 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

5. Currency.
6. Fair value of the derivative instrument at the close of the reporting month.
7. Amount of total accumulated gain / loss in the year for financial derivative instruments.
8. Other relevant or explanatory information at the Issuer's discretion.
   (...)»

In this sense, you are urged, within the framework of the duty of diligence, to adopt the necessary measures for the fulfillment of the aforementioned obligation, which has a due date of March 13, 20262.

Likewise, you are reminded that the important event must be sent using the "Formulario de posición mensual en Instrumentos Financieros Derivados" (Monthly Position in Financial Derivative Instruments Form), for which you must attach the template found in the important events section of the MVNet System3.

In the event that, as of the date of receipt of this circular, your company has complied with the aforementioned obligation, we would appreciate it if you disregard the previously indicated.

Finally, it should be noted that this circular does not require a response from your company; furthermore, this document is preventive and referential in nature, and therefore does not exempt your company from its responsibility to know and observe market regulations and to fully comply with its applicable information submission obligations.

Sincerely,

Alix Godos
General Superintendent
General Superintendence of Conduct Supervision

2 However, this deadline is subject to the provisions of Article 183, numeral 5 of the Peruvian Civil Code: "A deadline whose last day is a non-working day expires on the first following working day."
3 Use the corresponding path in MVNet: Information Obligations >> Important Events >> 18.1 Monthly position in financial derivative instruments.