Compilation of Pension Fund Control Regulations - Modifications based on Law No. 20.130 of May 2, 2023

1 Montevideo, November 23, 2023 Ref: COMPILATION OF PENSION FUND CONTROL REGULATIONS - Modifications based on Law No. 20.130 of May 2, 2023. The market is informed that the Financial Services Superintendence adopted the following resolution on November 21, 2023:

1. SUBSTITUTE in Chapter I – Equity and special reserve, of Title I BIS – Equity, special reserve and other provisions for Pension Savings Fund Administrators, of Book II – Stability and solvency, article 31 with the following:

ARTICLE 31 (PROCEDURE FOR CALCULATING THE SPECIAL RESERVE). Pension Savings Fund Administrators must integrate and maintain at all times a Special Reserve for each of the Subfunds of the Pension Savings Fund, the sole purpose of which is to cover the deficits of the minimum real profitability rate referred to in article 122 of Law No. 16.713 of September 3, 1995, which shall be set by the Financial Services Superintendence based on a percentage of the respective Pension Savings Fund, without prejudice to the rules and instructions of a particular nature that are issued according to technical risk coverage criteria.

This percentage will range between a minimum equivalent to 0.20% and a maximum equivalent to 2% of each of the Subfunds that make up the Pension Savings Fund, the total amount of the Special Reserve not being able to be less than 20% of the minimum capital required in article 30.4 and must be invested in shares of the corresponding subfunds.

The Financial Services Superintendence will communicate the percentage that must be applied for its calculation, which will enter into force 90 (ninety) days following its communication.

The calculation of the amount of the Special Reserve will be carried out based on each Pension Savings Subfund, on the last business day immediately preceding the date of calculation.

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2 In the event that on a certain day the Administrator maintains a Special Reserve higher than the maximum amount admitted for each Subfund, it must regularize the situation on the next business day after it is verified.

The movements of contributions or withdrawals of the Special Reserve by the Administrator must be carried out with available funds.

TRANSITIONAL PROVISION From December 1, 2023 and until a Communication is issued on this matter, the percentage that must be applied for the calculation of the special reserve will be 0.20% of each of the Subfunds that make up the Pension Savings Fund.

2. INCORPORATE into Book II – Stability and solvency, Title I BIS – Voluntary Pension Fund.

3. INCORPORATE into Title I BIS – Voluntary Pension Fund, of Book II – Stability and solvency, Chapter I – General provisions, which will contain the following article:

ARTICLE 35.1 (APPLICABLE REGIME). The provisions contained in articles 36.1, 38, 39 and 40 shall apply to the Voluntary Pension Fund. The reference to the Pension Savings Fund or to the Subfunds that make it up contained in said articles must be interpreted for these purposes as referring to the Voluntary Pension Fund.

4. INCORPORATE into Title I BIS – Voluntary Pension Fund, of Book II – Stability and solvency, Chapter II – Profitability, which will contain the following articles:

ARTICLE 35.2 (APPLICABLE REGIME). The provisions contained in articles 42 and 43 shall apply to the Voluntary Pension Fund. The reference to the Pension Savings Fund or to the Subfunds that make it up contained in said articles must be interpreted for these purposes as referring to the Voluntary Pension Fund.

ARTICLE 35.3 (BASE FOR DISTRIBUTION OF PROFITABILITY). The profitability of the assets of the Voluntary Pension Fund will be distributed among all individual accounts of affiliates, based on their participation at the close of the calculation day.

ARTICLE 35.4 (ANNUAL NOMINAL AND REAL PROFITABILITY RATES) Diagonal Fabini 777 - C.P. 11100 - Tel.: (598 2) 1967 - Montevideo, Uruguay - www.bcu.gub.uy CIRCULAR N°2438

3 The annual nominal profitability rate of the Voluntary Pension Fund is calculated by compounding the variation over the last 60 (sixty) months of the average fund share value.

The annual real profitability rate of the Voluntary Pension Fund is calculated by compounding the accumulation of the monthly real profitability rates of the last 60 (sixty) months, which will arise from deflating the average fund share value by the value of the adjustable unit.

The calculation of these rates will be carried out monthly according to the instructions that will be issued.

While the Voluntary Savings Fund has less than 60 (sixty) months of operation, the annual nominal and real profitability rate will be calculated as follows: A. Until the twelfth month, the compounded variation (without annualizing) of the value, measured in adjustable units for the case of real profitability rates, since its creation. B. From the thirteenth month onwards, compounding the variation of the share value, measured in adjustable units for the case of real profitability rates, since its creation.

5. INCORPORATE into Title I BIS – Voluntary Pension Fund, of Book II – Stability and solvency, Chapter III – Conditions for the investment of the assets of the Voluntary Pension Fund, which will contain the following article:

ARTICLE 35.5 (APPLICABLE REGIME). The Voluntary Pension Fund will be constituted by temporary availability and the investments made. The aforementioned investments must comply with the provisions of the laws and regulatory decrees in force and the provisions established by the Financial Services Superintendence. The provisions contained in articles 48 to 57 shall apply to the Voluntary Pension Fund. The reference to the Pension Savings Fund or to the Subfunds that make it up contained in said articles must be interpreted for these purposes as referring to the Voluntary Pension Fund.

6. INCORPORATE into Title I BIS – Voluntary Pension Fund, of Book II – Stability and solvency, Chapter IV – Permitted Investments, which will contain the following article:

ARTICLE 35.6 (APPLICABLE REGIME). The investment regime of the Voluntary Pension Fund will replicate that corresponding to the Accumulation Subfund. Consequently, the provisions contained in articles 58 to 74 shall apply to the Voluntary Pension Fund. The reference to the Pension Savings Fund or to the Subfunds that make it up contained in said articles must be interpreted for these purposes as referring to the Voluntary Pension Fund in those articles in which it is not expressly mentioned.

7. INCORPORATE into Title I BIS – Voluntary Pension Fund, of Book II – Stability and solvency, Chapter V – Investment Limits, which will contain the following articles:

ARTICLE 35.7 (APPLICABLE REGIME). The investment limit regime of the Voluntary Pension Fund will replicate that corresponding to the Accumulation Subfund, in case there is no express reference. Consequently, the provisions contained in article 123 bis of Law No. 16.713 of September 3, 1995 and its amendments and in articles 75 to 84 shall apply to the Voluntary Pension Fund. The reference to the Pension Savings Fund or to the Subfunds that make it up contained in said articles must be interpreted for these purposes as referring to the Voluntary Pension Fund in those articles in which it is not expressly mentioned.

ARTICLE 35.8 (INVESTMENT LIMIT IN SECURITIES ISSUED BY THE URUGUAYAN STATE AND BY THE CENTRAL BANK OF URUGUAY). Investments in letter A) of article 123 of Law No. 16.713 of September 3, 1995 and its amendments may reach up to 100% (one hundred percent) of the value of the asset of the Voluntary Pension Fund until it represents 5% (five percent) of the Accumulation Subfund. Once this percentage is reached, the investment limit will be reduced until it converges to that provided in article 123 bis of Law No. 16.713 of September 3, 1995 and its amendments, according to the instructions that will be issued in due course.

8. INCORPORATE into Title I BIS – Voluntary Pension Fund, of Book II – Stability and solvency, Chapter VI – Temporary Availability, which will contain the following article:

ARTICLE 35.9 (APPLICABLE REGIME). The provisions contained in articles 85 to 87 shall apply to the Voluntary Pension Fund. The reference to the Pension Savings Fund or to the Subfunds that make it up contained in said articles must be interpreted for these purposes as referring to the Voluntary Pension Fund.

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5 9. INCORPORATE into Title I BIS – Voluntary Pension Fund, of Book II – Stability and solvency, Chapter VII – Valuation, which will contain the following article:

ARTICLE 35.10 (APPLICABLE REGIME). The provisions contained in articles 88 to 100 shall apply to the Voluntary Pension Fund. The reference to the Pension Savings Fund or to the Subfunds that make it up contained in said articles must be interpreted for these purposes as referring to the Voluntary Pension Fund.

10. SUBSTITUTE in Chapter I – General provisions, of Title II – Pension Savings Fund, of Book II – Stability and solvency, articles 36 and 37 with the following:

ARTICLE 36 (COMPOSITION OF THE PENSION SAVINGS FUND). The Pension Savings Fund will be composed of three Subfunds named Growth Subfund, Accumulation Subfund and Withdrawal Subfund, which include their respective Profitability Fluctuation Subfunds.

TRANSITIONAL PROVISION: The initial transfer of assets from the Accumulation Subfund to the Growth Subfund must be carried out proportionally, respecting the composition by instruments of the assets that make up the investment portfolio of the Accumulation Subfund as of November 30, 2023, excluding temporary availability and the instruments of letter E) of article 123 of Law No. 16.713 of September 3, 1995 and its amendments. In addition, the existence of indivisible instruments, instruments with a minimum divisibility unit and the corresponding regulatory restrictions must be taken into account. Likewise, with respect to the instruments of letters C) and F) of the aforementioned Law, the complete investments (undivided) that are in the accumulation subfund must be transferred, respecting the participation of each letter in the growth subfund.

ARTICLE 37 (VARIATION IN THE NUMBER OF SHARES). The number of shares of each Pension Savings Subfund is modified when any of the following events occur: a. Collection of amounts destined to the savings regime established in letters A) to C) of article 45 of Law No. 16.713 of September 3, 1995 and its amendments, net of administration and custody commissions and collective insurance premiums for disability and death.

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6 b. Inflows or outflows of funds transferred between Administrators according to the option made by the affiliate. c. Refund of funds to the affiliate or their successors carried out in compliance with the provisions of articles 52, 58 and 58 bis of Law No. 16.713 of September 3, 1995 and its amendments. d. Transfers of funds to insurance companies. e. Transfers from and to the respective Profitability Fluctuation Subfund. f. Transfers from the Growth Subfund to the Accumulation Subfund and from this to the Withdrawal Subfund. g. Transfers from and to the Special Reserve. h. Transfers of funds to the Social Prevision Bank or the corresponding pension institute, for the concept of disaffiliations, revocations of options or annulments of affiliations. i. Benefits paid to those affiliates in a terminal illness situation according to the provisions of article 6 of Law No. 16.713 of September 3, 1995 and its amendments. j. Payment of the partial benefit in the form of capital to affiliates who have made the option provided for in article 87 of Law No. 20.130 of May 2, 2023. k. Inflows or outflows of funds for any other concept instructed by the Financial Services Superintendence.

The variations that occur in the number of shares of each Pension Savings Subfund will take effect from the day the respective event occurred and it will be valued according to the quote of the share of the respective Subfund, of the immediately preceding business day.

11. SUBSTITUTE in Section I – Base for distribution of profitability, of Chapter II – Profitability, of Title II – Pension Savings Fund, of Book II – Stability and solvency, article 41 with the following:

ARTICLE 41 (BASE FOR DISTRIBUTION OF PROFITABILITY). The profitability of the assets of each Pension Savings Subfund will be distributed among: i) all individual accounts of affiliates, ii) the respective Profitability Fluctuation Subfund, and Diagonal Fabini 777 - C.P. 11100 - Tel.: (598 2) 1967 - Montevideo, Uruguay - www.bcu.gub.uy CIRCULAR N°2438

7 iii) the Pension Savings Fund Administrator account - respective Special Reserve, based on their participation at the close of the calculation day.

12. SUBSTITUTE in Section II – Profitability rates of the subfunds of Chapter II – Profitability, of Title II – Pension Savings Fund, of Book II – Stability and solvency, articles 44 and 45 with the following:

ARTICLE 44 (ANNUAL NOMINAL AND REAL PROFITABILITY RATES) The annual nominal profitability rate of the Growth, Accumulation and Withdrawal Subfunds is calculated by compounding the variation over the last 60 (sixty) months of the average share value of the respective Subfund. The annual real profitability rate of the Growth, Accumulation and Withdrawal Subfunds is calculated by compounding the accumulation of the monthly real profitability rates of the last 60 (sixty) months, which will arise from deflating the average share value of the respective Subfund by the value of the adjustable unit. The calculation of these rates will be carried out monthly, according to the instructions that will be issued.

While the Growth Subfund has less than 60 (sixty) months of operation, the profitability rate corresponding to said subfund will be calculated by splicing the observed figures with those corresponding to the Accumulation Subfund until the 60-month period is totaled.

ARTICLE 45 (AVERAGE PROFITABILITY RATES OF THE REGIME FOR EACH SUBFUND). The average nominal and real profitability rates of the regime will be calculated separately for each Subfund.

13. INCORPORATE into Section II – Profitability rates of the subfunds, of Chapter II – Profitability, of Title II – Pension Savings Fund, of Book II – Stability and solvency, the following article:

ARTICLE 45.1 (AVERAGE PROFITABILITY RATES OF THE PENSION SAVINGS FUND). The average profitability rates of the Pension Savings Fund will be determined for each Pension Savings Fund Administrator according to the following quotient: the numerator will be represented by the sum of the amount of each subfund by its respective rate and the denominator by the total sum of the subfunds.

14. SUBSTITUTE in Section II – Profitability rates of the subfunds of Chapter II – Profitability, of Title II – Pension Savings Fund, of Book II – Stability and solvency, article 46 with the following:

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8 ARTICLE 46 (NET PROFITABILITY RATE AND AGGREGATED NET PROFITABILITY RATE). The net profitability rate and aggregated net profitability rate will comply with the provisions of Law No. 16.713 of September 3, 1995 and its amendments and its regulatory decrees in force.

15. SUBSTITUTE in Chapter III – Conditions for the investment of the assets of the pension savings subfunds, of Title II – Pension Savings Fund, of Book II – Stability and solvency, article 47 with the following:

ARTICLE 47 (APPLICABLE REGIME AND DEFINITIONS). The investments that make up the asset of each Pension Savings Subfund must comply with the provisions of the laws and regulatory decrees in force and the provisions established by the Financial Services Superintendence. The Growth, Accumulation and Withdrawal Subfunds will be composed of the total asset of each Subfund minus the respective special reserve, which will be considered as a liability for all purposes that correspond.

16. INCORPORATE into Chapter III – Conditions for the investment of the assets of the pension savings subfunds, of Title II – Pension Savings Fund, of Book II – Stability and solvency, the following article:

ARTICLE 47.1 (WITHDRAWAL SUBFUND – REMAINING MATURITY OF INVESTMENTS) Investments in securities and placements permitted for the Withdrawal Subfund according to the provisions of article 123 of Law No. 16.713 of September 3, 1995 and its amendments must have a remaining maturity of up to 5 (five) years.

17. SUBSTITUTE in Chapter III – Conditions for the investment of the assets of the pension savings subfunds, of Title II – Pension Savings Fund, of Book II – Stability and solvency, article 50 with the following:

ARTICLE 50 (PRIMARY MARKET). Investments permitted within the framework of letters A) and F) of article 123 of Law No. 16.713 of September 3, 1995 and its amendments may be acquired in the primary market.

Investments within the framework of letter B) of article 123 of Law No. 16.713 of September 3, 1995 and its amendments may be acquired in the primary market, provided they meet the following conditions:

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9 a. There is a public offer of securities to which all Pension Savings Fund Administrators are invited. b. That they have been rated by institutions registered in the Securities Market Registry.

When it comes to emissions placed directly by the issuer or a placement agent, in addition to the conditions previously provided, the following requirements must be met: i. existence of a placement procedure where all administrators have equal access; ii. in the event that there is excess demand on the total of the emission, the issuer must commit to:

• when it comes to placement procedures by quantity at a single price, to allocate it pro rata to all requests made.
• when it comes to bidding procedures by price, to allocate the excess demand at the closing price pro rata to the requests made at that price.

Investments within the framework of letter D) of article 123 of Law No. 16.713 of September 3, 1995 and its amendments may be acquired in the primary market, provided they meet the following conditions: a. That they have been rated by institutions registered in the Securities Market Registry. b. That they trade on some local or foreign formal market, c. That they have information on their public quotation without restrictions for access to it, on a daily basis.

18. RENAME Section I – Securities issued by the uruguayan state, of Chapter IV – Permitted Investments, of Title II – Pension Savings Fund, of Book II – Stability and solvency, which will be renamed Section I – Securities issued by the uruguayan state and by the Central Bank of Uruguay.

19. SUBSTITUTE in Section I – Securities issued by the uruguayan state and by the Central Bank of Uruguay, of Chapter IV – Permitted Investments, of Title II – Pension Savings Fund, of Book II – Stability and solvency, article 58 with the following:

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10 ARTICLE 58 (SECURITIES ISSUED BY THE URUGUAYAN STATE AND BY THE CENTRAL BANK OF URUGUAY). Fund administrator companies may invest the resources of the Pension Savings Fund in securities issued by the Uruguayan State and by the Central Bank of Uruguay in accordance with the provisions of Article 123 Lit. A) of Law No. 16.713 of September 3, 1995 and its amendments. To this end, securities issued by the Central Government and by Departmental Governments shall be considered as securities issued by the Uruguayan State.

20. SUBSTITUTE in Section II – Securities issued by public or private companies, financial trusts and investment funds, of Chapter IV – Permitted Investments, of Title II – Pension Savings Fund, of Book II – Stability and Solvency, Articles 59, 59.1, 60 and 61.1 with the following:

ARTICLE 59 (SECURITIES ISSUED BY COMPANIES, FINANCIAL TRUSTS OR INVESTMENT FUNDS). The securities referred to in literal B) of Article 123 of Law No. 16.713 of September 3, 1995 and its amendments, must meet the following requirements: a) Be registered in the Securities Market Registry. b) Trade on some local formal market registered in the Securities Market Registry or on some formal foreign market, having to have information about their public quotation without restrictions for access to the same, on a daily basis. c) Have a risk rating issued by rating institutions registered in the Securities Market Registry. The rating cannot be lower than that corresponding to Category 3 for long-term securities and Category 2 for short-term securities, according to the definitions given in Article 54, for the securities that make up the asset of the Growth and Accumulation Subfunds. Regarding the Retirement Subfund, the rating of the aforementioned securities cannot be lower than Category 2 for long-term securities and Category 1 for short-term securities. The existence of a minimum rating does not exempt Administrators from their responsibilities and obligations regarding the good administration of the Pension Funds. d) Not be representative of investments not permitted for the Pension Savings Fund according to what is established in Article 124 of Law No. 16.713 of September 3, 1995 and amendments.

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11 ARTICLE 59.1 (SECURITIES ISSUED BY FINANCIAL TRUSTS - COMPOSITION OF THE TRUST) Financial trusts in whose participation certificates, debt titles or mixed public offer titles the resources of the Pension Savings Fund are invested may be constituted by any type of goods located in the country, as well as by securities issued in public or private offer regime by Uruguayan companies. In the case of the Retirement Subfund, investments can only be made in long-term debt titles issued by financial trusts that have a risk rating not lower than category 2, according to the definitions given in Article 54.

ARTICLE 60 (INVESTMENT IN SHARES). The Pension Savings Fund and the Voluntary Pension Fund considered jointly may hold up to the equivalent of 20% (twenty percent) of the total shares issued (ordinary, preferred or dividend) by a Uruguayan joint-stock company, provided that control or significant influence is not configured, as provided in the appropriate accounting standards for commercial companies. Likewise, such investment cannot exceed 15% (fifteen percent) of the total shares issued in the case of the Growth Subfund, 10% (ten percent) in the case of the Accumulation Subfund and 10% (ten percent) in the case of the Voluntary Pension Fund. Investments in shares in the Retirement Subfund are not admitted. For the purposes of this limit, "pase" or "report" operations whose object value is shares will be counted.

ARTICLE 61.1 (INVESTMENT COMMITMENTS, SUBSCRIPTION OR INTEGRATION ON A FUTURE DATE). Fund Administrators may assume, with prior authorization from the Superintendency of Financial Services, commitments of investment, subscription or integration on future dates in order to invest the resources of the Growth and Accumulation Subfunds and of the Voluntary Pension Fund they administer, in the investments mentioned in literal B) of Article 123 of Law No. 16.713 of September 3, 1995 and amendments. Such commitments must meet the following conditions: a) be assumed for a term not exceeding five years to make the investments. b) the sum of the commitments cannot exceed 25% (twenty-five percent) of the asset value of the Accumulation and

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12 Growth Subfunds and of the Voluntary Pension Fund considered individually. c) the sum of the commitments assumed plus the investments in securities of the aforementioned literal B) cannot exceed the limit established for said literal. d) when it corresponds to make effective the committed financing, the securities to be acquired must meet the requirements demanded in this Compilation. For the purposes of granting authorization, Administrators must present the text of the commitment to be signed, accompanied by the following information:

• background of the project executor, along with sufficient information that accredits its patrimonial and technical solvency.
• Conditions of the contract on which the business is based, including business plan and cash flow.
• technical evaluation of the project carried out by the competent bodies of the Administrator accompanied by the minutes that motivated the request for authorization. The Superintendency of Financial Services may demand additional information to that detailed above as well as additional conditions in cases it deems convenient. Investment, subscription or integration commitments on future dates cannot be assumed in the Retirement Subfund.

21. SUBSTITUTE in Section III – Deposits in financial intermediation institutions, of Chapter IV – Permitted Investments, of Title II – Pension Savings Fund, of Book II – Stability and Solvency, Articles 62, 63, 64 and 65 with the following:

ARTICLE 62 (LOCATION OF DEPOSITS IN FINANCIAL INTERMEDIATION INSTITUTIONS). Deposits made in financial intermediation institutions, referred to in literal C) of Article 123 of Law No. 16.713 of September 3, 1995 and amendments, must be located in the country, no exceptions of any kind being admitted. Deposits corresponding to the Retirement Subfund must be made in institutions that have a risk rating not lower than that corresponding to category 1 according to the definition given in Article 54.

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13 ARTICLE 63 (TIME DEPOSITS IN NATIONAL OR FOREIGN CURRENCY). Time deposits in national or foreign currency, to which literal C) of Article 123 of Law No. 16.713 of September 3, 1995 and amendments refers, must be constituted in the form of Certificates of Deposit. The obligation to document these investments through the issuance of a deposit certificate does not change the nature of the investment for all legal and regulatory purposes.

ARTICLE 64 (OTHER CERTIFICATES OF DEPOSIT). Administrators may place the assets of the Pension Savings Fund in Certificates of Deposit, as long as the following conditions are cumulatively configured: a. that the Certificates are constituted in dollars, euros, yen, pounds sterling, national currency, pension units, adjustable units, indexed units or reais. b. be at fixed or variable rate, as long as the return of the initial capital is guaranteed at minimum. c. be issued by financial intermediation institutions that have a risk rating - according to the definitions given in Article 54 - not lower than that corresponding to:

• category 2, for Certificates issued for terms less than or equal to one year.
• category 1, for Certificates issued for terms greater than one year and less than ten years. To invest the assets of the Pension Savings Fund in Certificates of Deposit that do not meet the aforementioned conditions, Administrators must have prior authorization from the Superintendency of Financial Services.

ARTICLE 65 (SETTLEMENT DATE). The settlement date of investments within the framework of literal C) of Article 123 of Law No. 16.713 of September 3, 1995 and amendments, cannot exceed two business days. In the case of deposit certificates referred to in Article 64, at the time of authorization a different settlement date may be established.

22. SUBSTITUTE in Section IV – Fixed income securities issued abroad, of Chapter IV – Permitted Investments, of Title II – Pension Savings Fund, of Book II – Stability and Solvency, Article 67 with the following:

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14 ARTICLE 67 (INVESTMENTS IN FIXED INCOME SECURITIES ISSUED BY INTERNATIONAL CREDIT ORGANISMS AND FOREIGN GOVERNMENTS). For the purposes of carrying out investments in fixed income securities issued by international credit organizations and foreign governments referred to in literal D) of Article 123 of Law No. 16.713 of September 3, 1995 and amendments, Pension Fund Administrators must request authorization from the Superintendency of Financial Services, for which purposes they must present the following information:

1. documentation that accredits the conditions established by Article 66;
2. complete information on the terms and conditions of the titles to be acquired, including the venue where they are registered, the formal market in which they trade, term, currency of issuance, yield, eventual guarantees and other characteristics established in the corresponding issuance document;
3. risk rating opinion of the securities. The Superintendency of Financial Services may require additional documentation and information to that indicated above when it deems it pertinent, for the purposes of adopting a founded decision on the authorization request. Additionally, they must meet the following requirements: a) trade on some local or foreign formal market, having to have information about their public quotation without restrictions for access to the same, on a daily basis, b) not be representative of financial indices for those values in which the Retirement Subfund invests, c) in the case of fixed income securities issued by foreign governments, have a risk rating not lower than Category 1, according to the definition given in Article 54. d) the investments made cannot exceed 15% (fifteen percent) of the assets of the Pension Savings Fund and of the Voluntary Pension Fund considered individually. Likewise, Pension Fund Administrators must send to the Superintendency of Financial Services, prior to the negotiation of the operation, information on the issuer and the securities according to the instructions that will be imparted.

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15 TRANSITIONAL PROVISION: For the purposes of compliance with these requirements, securities acquired prior to the entry into force of this resolution will not be considered.

23. SUBSTITUTE in Section V – Financial instruments whose object is the coverage of risk, of Chapter IV – Permitted Investments, of Title II – Pension Savings Fund, of Book II – Stability and Solvency, Article 68 with the following:

ARTICLE 68 (DEFINITION OF COVERAGE). For the purposes that Administrators of Pension Funds can invest the assets of the Pension Savings Fund in the placements provided for in literal E) of Article 123 of Law No. 16.713 of September 3, 1995 and amendments, coverage of an observable and measurable risk will be understood as assuming a position or combination of positions – in financial instruments, that produce results that vary inversely with the results of the elements whose risks are intended to be covered.

24. INCORPORATE in Section V – Financial instruments whose object is the coverage of risk, of Chapter IV – Permitted Investments, of Title II – Pension Savings Fund, of Book II – Stability and Solvency, the following article:

ARTICLE 68.1 (INVESTMENTS IN FINANCIAL INSTRUMENTS ISSUED BY FOREIGN INSTITUTIONS). For the purposes of investing in financial instruments issued by foreign institutions whose object is the coverage of financial risks of the Pension Savings Fund, the aforementioned institutions must have an international risk rating not lower than Category 2, according to the definition given in Article 54.

25. SUBSTITUTE in Section VI – Loans to affiliates and beneficiaries of the system, of Chapter IV – Permitted Investments, of Title II – Pension Savings Fund, of Book II – Stability and Solvency, Articles 72 and 73 with the following:

ARTICLE 72 (LOANS GUARANTEED BY PUBLIC OR PRIVATE INSTITUTIONS). For the purposes that Administrators of Pension Funds can invest the assets of the Pension Savings Fund in the placements provided for in literal F) of Article 123 of Law No. 16.713 of September 3, 1995 and amendments, in accordance with the limitations provided in the aforementioned norm, the following provisions must be met: a. (Documentation) An agreement must be signed between the Administrator and the entity that guarantees the operation and, for each group of personal loans derived from identical conditions, a voucher will be signed that

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16 will be the document that supports the investment. With respect to the investments of the Retirement Subfund, the entity that guarantees the operation must be a public institution. In both cases, all agreed conditions will be clearly established, especially a reference that the investment is made within the framework of literal F) of Article 123 of Law No. 16.713 of September 3, 1995 and amendments, and that the guarantor entity obligates itself to the payment of the total loan, independently of the collection of the loans it grants. b. (Custody of titles) The vouchers that support the investment will be subject to the custody established in Article 126 of Law No. 16.713 of September 3, 1995. c. (Instrumentation of payments) The payments of the installments that derive from the investment will be instrumented under the modality of debits to the account (or accounts) that the guarantor entity maintains in this Central Bank, with credit in the respective accounts of the Administrator. d. (Term and Interest Rate) The investment will adjust to the limits of maximum term and minimum interest rate that the aforementioned literal F) establishes. A correspondence must be maintained regarding term and interest rate between the main placement and the derived personal loans, admitting a differential in the rate of the derived personal loans duly justified for the purposes of covering administrative costs and the individual risk of default. e. (Investment Limits) Up to 3% (three percent) of the asset value of each Pension Savings Subfund may be invested in placements guaranteed by the same institution, institutions belonging to the same economic group (according to the definition given in Article 271 of the Compilation of Rules for the Regulation and Control of the Financial System) or affiliated companies. In case that the guarantor institutions are rated in Category 1 of numeral 2) of Article 54, said limit will be expanded up to 5% (five percent). This expansion will also apply when the aforementioned investments are guaranteed by the Social Prevision Bank. f. (Administration of personal loans) The guarantor institution will administer the derived personal loans, having to accredit to the Administrator that they have been made. g. (Control of compliance with legal provisions) The Administrator must conserve all the documentation that supports the placement jointly with, at least, copies of the vouchers signed by the personal loans, verifying the compliance with what is established in the law and its regulatory norms and that the sum of the installments to be collected

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17 in each amortization of the derived personal loans coincides with the respective installment of the main placement. h. (Accounting) Each voucher will be accounted for as an investment made within the framework of the aforementioned literal F). i. (Valuation) The valuation will be carried out according to what is established in Article 96 of this Compilation. The operation must be authorized in advance by the Superintendency of Financial Services, which may demand additional conditions in particular cases, for the purposes of mitigating the risks associated with each operation.

ARTICLE 73 (MAXIMUM RATE OF PLACEMENTS AND DERIVED PERSONAL LOANS). Pension Fund Administrators must adopt the necessary measures to guarantee that, at all times, the interest rate of the placements they carry out within the framework of literal F) of Article 123 of Law No. 16.713 of September 3, 1995 and amendments, as well as that of the derived personal loans, adjust to the provisions on maximum rate recorded in Law No. 18.212 of December 22, 2007. In cases where the minimum interest established by the aforementioned literal F) results in a rate higher than the maximum interest set by Law No. 18.212, the latter will prevail.

26. SUBSTITUTE in Chapter V – Investment Limits, of Title II – Pension Savings Fund, of Book II – Stability and Solvency, Articles 75, 76, 77, 78, 79, 79.1, 79.2, 79.3, 79.3.1, 79.4, 79.5, 80, 80.1, 80.2, 81 and 83 with the following:

ARTICLE 75 (LIMIT BY MONETARY POSITION). The resources of the asset of the Pension Savings Fund may be invested in securities denominated in foreign currency in a proportion not greater than 45% (forty-five percent) of the asset of the Growth Subfund, to 40% (forty percent) of the asset of the Accumulation Subfund and to 15% (fifteen percent) of the asset of the Retirement Subfund. The resources of the asset of the Voluntary Pension Fund may be invested in securities denominated in foreign currency in a proportion not greater than 40% (forty percent) of its asset. For the purposes of calculating this limit, forward operations will be counted from the moment of their negotiation, taking into account the cash position plus the net forward position in foreign currency.

ARTICLE 76 (CAP ON PURCHASE AND SALE OF THE SAME INSTRUMENT ON THE SAME DAY). Pension Fund Administrators may carry out purchases for the asset of each Subfund with subsequent sale, or vice versa, of the same instrument and on the same day, up to 1% (one percent) of the value of the asset of said Subfund the previous day. In the case of the Voluntary Pension Fund, the aforementioned cap will be up to the maximum between 3% (three percent) of the value of the asset of said Fund the previous day and the equivalent to 500,000 UI (five hundred thousand indexed units). The purchase and sale of foreign currency on the same day will adjust to the provisions issued by the Superintendency of Financial Services.

ARTICLE 77 (LIMITS BY ISSUER). The limits by issuer are the following:

1. The sum of the investments in literals B) and F) of Article 123 of Law No. 16.713 of September 3, 1995 and amendments, issued or guaranteed by the same institution or institutions belonging to the same economic group, according to the definition given in Article 271 of the Compilation of Rules for the Regulation and Control of the Financial System, cannot exceed 3% (three percent) of the asset value of the Pension Savings Fund and of the Voluntary Pension Fund considered jointly. Likewise, investments in instruments of literal B) rated in Category 3 of numeral 2) of Article 54 will not exceed 1% (one percent) of the asset value of the Growth, Accumulation Subfunds and of the Voluntary Pension Fund considered individually. In the case that the risk rating of the issuing or guarantor institutions and of all instruments of literal B) issued by the same are in Category 1, according to the definitions given in Article 54, said limit will be expanded up to 5% (five percent). Investments in shares of Investment Funds and in instruments representative of financial trusts are excluded - for the computation of the aforementioned limits -.
2. The sum of the Temporary Liquidity, the investments in literals C) and E) of Article 123 of Law No. 16.713 of September 3, 1995 and amendments, and "pase" or "report" operations cannot exceed in a single financial intermediation institution, 15% (fifteen percent) of the asset value of each Subfund and of the Voluntary Pension Fund considered individually.

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19 In "pase" or "report" operations, the institution issuing the security involved will be counted within the limits of the counterparty institution, the value of which will be calculated based on the valuation of the "pase" or "report" operation. 3) Investments in instruments of literal D) of article 123 of Law No. 16.713 of September 3, 1995 and amendments, in securities issued by the same foreign government, shall not exceed 5% (five percent) of the value of the assets of each Subfund and the Voluntary Pension Fund considered individually. Investments in instruments of literal D) of article 123 of Law No. 16.713 of September 3, 1995 and amendments, in securities issued by the same international credit organization, shall not exceed 5% (five percent) of the value of the assets of each Subfund and the Voluntary Pension Fund considered individually. In the event that the risk rating of all instruments from the same issuing organization is in Category 1 according to the definitions given by article 54, these limits will be expanded up to 10% (ten percent) of the value of the assets of the respective Pension Savings Subfund and the Voluntary Pension Fund considered individually.

ARTICLE 78 (LIMIT ON TIME DEPOSITS IN FINANCIAL INTERMEDIATION INSTITUTIONS BASED ON THEIR ECONOMIC GROUP). The sum of time deposits made in financial intermediation institutions, installed in the country, with which Administrators are linked by belonging to the same economic group, according to the definition given by article 271 of the Compilation of Rules for the Regulation and Control of the Financial System, shall not exceed 10% (ten percent) of the value of the assets of each Subfund and the Voluntary Pension Fund considered individually.

ARTICLE 79 (LIMIT ON INVESTMENT IN FINANCIAL INTERMEDIATION INSTITUTIONS BASED ON THEIR NET EQUITY LIABILITY). The total of investments of the resources of the Pension Savings Fund and the Voluntary Pension Fund considered jointly, in instruments issued or guaranteed by the same financial intermediation institution, shall not exceed 10% (ten percent) of its Net Equity Liability (according to the definition established in the Compilation of Rules for the Regulation and Control of the Financial System). This limit may reach 20% (twenty percent) of the Net Equity Liability of the financial intermediation institution, provided that it has a risk rating belonging to Category 2 as referred to in article 54, and up to 50% (fifty percent) of the Net Equity Liability, if its rating were in Category 1 referred to in said article. Investments made in financial trusts administered and mortgage credit notes issued by financial intermediation institutions are exempt from the aforementioned limits.

ARTICLE 79.1 (LIMIT ON INVESTMENT BY SERIES OF NEGOTIABLE OBLIGATIONS). The investment of the resources of the Pension Savings Fund and the Voluntary Pension Fund considered jointly, in negotiable obligations, shall not exceed 70% (seventy percent) of the amount issued and in circulation of each series. In the primary placement of these instruments, this percentage will be verified on the amount effectively placed. For the purposes of this limit, "pase" or "report" operations whose object is negotiable obligations will be counted. Excesses derived from the exercise of partial redemption options will not be considered. The Superintendence of Financial Services will inform the amount in circulation of each series for the purposes of calculating the limit established in the first paragraph of this article. TRANSITIONAL PROVISION: The holding of negotiable obligations that exceeds this limit will not be considered an excess when they were acquired prior to the entry into force of Circular 2328 of November 15, 2019.

ARTICLE 79.2 (LIMIT ON INVESTMENT IN SHARES FOR EACH CLOSED-END INVESTMENT FUND). The investment of the resources of the Pension Savings Fund and the Voluntary Pension Fund considered jointly, in shares of closed-end investment funds, shall not exceed 70% (seventy percent) of the amount issued and in circulation of each fund. In the primary placement of these instruments, this percentage will be verified on the amount effectively placed. For the purposes of this limit, "pase" or "report" operations whose object is shares of closed-end investment funds will be counted. Excesses derived from the exercise of partial redemption options will not be considered. The Superintendence of Financial Services will inform the amount in circulation of each fund for the purposes of calculating the limit established in the first paragraph of this article.

ARTICLE 79.3 (LIMIT ON INVESTMENT PER ISSUE MADE BY FINANCIAL TRUSTS). The investment of the resources of the Pension Savings Fund and the Voluntary Pension Fund considered jointly, in public offer securities issued by the same financial trust, shall not exceed 70% (seventy percent) of the issue of securities in circulation. The Superintendence of Financial Services will inform the amount in circulation of each trust for the purposes of calculating the limit established in the first paragraph of this article. TRANSITIONAL PROVISION: The holding of securities issued by financial trusts that exceeds this limit will not be considered an excess when they were acquired prior to the entry into force of Circular 2328 of November 15, 2019, or subsequently by commitments assumed previously within the framework of what is provided in article 61.1.

ARTICLE 79.3.1 (LIMIT ON INVESTMENT IN PUBLIC OR PRIVATE OFFER SECURITIES ISSUED BY URUGUAYAN COMPANIES THAT ARE PART OF FINANCIAL TRUSTS). The limits per issuer and per issue established in this Chapter will apply to public or private offer securities issued by Uruguayan companies, which are part of financial trusts in which the Growth Subfund, the Accumulation Subfund, and the Voluntary Pension Fund invest. When it comes to shares or other securities representing capital, the limit established in article 60 will apply. The aforementioned limit will not apply when the company meets the following conditions: a) The company does not develop business activity except that linked to the holding of real estate, its object being limited to the purchase, sale, lease, or usufruct of real estate located in the country or its delivery to third parties through the concession of other personal or real rights. b) The exploitation activities of said real estate are contracted with third parties. c) Decisions related to the real estate in compliance with the purpose of the trust are adopted exclusively by the trustee. d) The risks associated with the development of the object of the trust are not increased by the acquisition of the company's shares.

ARTICLE 79.4 (LIMIT ON INVESTMENT IN INSTRUMENTS OF LITERAL B) OF ARTICLE 123 OF LAW 16.713 BY ACTIVITY SECTOR). Investments in public offer securities in instruments of literal B) of article 123 of Law No. 16.713 of September 3, 1995 and amendments, corresponding to the same activity sector – defined according to the instructions that will be issued – shall not exceed 15% (fifteen percent) of the value of the assets of the Growth, Accumulation Subfunds, and the Voluntary Pension Fund considered individually, and 8% (eight percent) of the value of the assets of the Retirement Subfund, except those whose object is to finance the execution of works within the framework of public-private participation contracts referred to in Law No. 18.786 of July 19, 2011. For the purpose of determining in which activity sector an investment is included, the sector from which the payment risk of the instrument originates shall be considered. TRANSITIONAL PROVISION: The holding of instruments of literal B) of article 123 of Law No. 16.713 of September 3, 1995 and amendments that exceeds this limit will not be considered an excess when they were acquired prior to the entry into force of Circular 2328 of November 15, 2019, or subsequently by commitments assumed previously within the framework of what is provided in article 61.1.

ARTICLE 79.5 (LIMIT ON INVESTMENT IN INSTRUMENTS OF LITERAL B) OF ARTICLE 123 OF LAW 16.713 WHOSE OBJECT IS TO FINANCE THE EXECUTION OF WORKS WITHIN THE FRAMEWORK OF PUBLIC-PRIVATE PARTICIPATION CONTRACTS). Investments in public offer securities in instruments of literal B) of article 123 of Law No. 16.713 of September 3, 1995 and amendments, whose object is to finance the execution of works within the framework of public-private participation contracts referred to in Law No. 18.786 of July 19, 2011, in which cash flows are generated for the contracting Public Administration derived from the project's infrastructure, shall not exceed 20% (twenty percent) of the value of the assets of the Growth, Accumulation Subfunds, and the Voluntary Pension Fund considered individually, nor 15% (fifteen percent) of the value of the assets of the Retirement Subfund. For their part, investments in instruments of literal B) whose object is to finance the execution of works within the framework of public-private participation contracts referred to in the aforementioned law that do not generate the aforementioned cash flows must meet the following conditions:

• they shall not exceed 15% (fifteen percent) of the value of the assets of the Growth, Accumulation Subfunds, and the Voluntary Pension Fund considered individually, nor 10% (ten percent) of the value of the assets of the Retirement Subfund, and
• the sum of said investments and investments in securities issued by the Uruguayan State shall not exceed 75% (seventy-five percent) of the value of the assets of the Growth and Accumulation Subfunds, nor 90% of the value of the assets of the Retirement Subfund. TRANSITIONAL PROVISION: The holding of instruments of literal B) of article 123 of Law No. 16.713 of September 3, 1995 and amendments whose object is to finance public-private participation contracts that exceeds this limit will not be considered an excess when they were acquired prior to the entry into force of Circular 2328 of November 15, 2019, or subsequently by commitments assumed previously within the framework of what is provided in article 61.1.

ARTICLE 80 (LIMIT PER ADMINISTRATOR OF INVESTMENT FUNDS OR TRUSTEE AND THEIR ECONOMIC GROUP). The sum of investments in instruments representing closed-end investment funds and financial trusts administered by the same investment fund administrator or the same trustee, or administrators and trustees members of the same economic group, according to the definition given by article 271 of the Compilation of Rules for the Regulation and Control of the Financial System, shall not exceed 20% (twenty percent) of the assets of the Growth, Accumulation Subfunds, and the Voluntary Pension Fund considered individually, nor 10% (ten percent) of the assets of the Retirement Subfund.

ARTICLE 80.1 (LIMIT ON INVESTMENT IN ISSUANCES OF INSTRUMENTS OF LIT. B) OF ART. 123 LAW 16.713 WITHOUT RETAIL TRANCHE). Investments of the resources of each Pension Savings Subfund and the Voluntary Pension Fund considered individually, in instruments of literal B) of article 123 of Law No. 16.713 of September 3, 1995 and its amendments, whose issuances do not have a retail tranche in the terms detailed below, shall not exceed, by December 31 of each year, 30% (thirty percent) of the total investments in the aforementioned literal. Securities issuances with a retail tranche will be considered those that meet the following conditions: i. The amount offered in the retail tranche represents at least 10% (ten percent) of the total amount of the issuance or 5% (five percent) in those issuances whose total allocation amount is greater than US$ 50,000,000 (fifty million US dollars) and the term is greater than 10 (ten) years. ii. The maximum denomination of the security is 10,000 UI (ten thousand indexed units) or its equivalent in the corresponding currency. iii. The maximum subscription value per investor in the retail tranche does not exceed 500,000 UI (five hundred thousand indexed units) or its equivalent in the corresponding currency. iv. The terms and conditions of the security do not differ between the retail and wholesale tranches. TRANSITIONAL PROVISION: For the purposes of determining the limit, values acquired prior to the entry into force of Circular No. 2255 of May 24, 2016 will not be considered, nor will investments made after that date in relation to commitments assumed previously within the framework of what is provided in article 61.1.

ARTICLE 80.2 (LIMIT ON INVESTMENT IN LONG-TERM INSTRUMENTS OF LIT. B) OF ART. 123 LAW 16.713 RATED IN CATEGORY 3). Investments in long-term instruments of literal B) of article 123 of Law No. 16.713 of September 3, 1995 and amendments, rated in Category 3 of numeral 2) of article 54, shall not exceed 5% (five percent) of the value of the assets of the Growth Subfund and 3% (three percent) of the value of the assets of the Accumulation Subfund and the Voluntary Pension Fund considered individually.

ARTICLE 81 (INVESTMENT EXCESSES). In the event that an investment made with resources from the assets of each Pension Savings Subfund or the Voluntary Pension Fund exceeds the limits or ceases to meet the requirements established for its eligibility, the Administrator shall not make new investments in the same instruments while such situation persists. This is without prejudice to the power of the Central Bank of Uruguay to apply the corresponding sanctions. If any of the instruments changes its risk rating category, no investment in more instruments from that issuer will be allowed while in a situation of excess.

ARTICLE 83 (PROHIBITION ON ALIENATION OF ASSETS). Sales and purchase operations between the assets of the Pension Savings Fund and the Voluntary Pension Fund and the own assets of the Administrator are prohibited. Likewise, sales and purchase operations of assets between the Pension Savings Subfunds of the Administrator and between them and the Voluntary Pension Fund are prohibited.

27. REPLACE in Chapter VI – Temporary Availability, of Title II – Pension Savings Fund, of Book II – Stability and solvency, article 87 with the following:

ARTICLE 87 (TEMPORARY AVAILABILITY CAP). In each Pension Savings Subfund, the Temporary Availability placed in Financial Intermediation Institutions shall not exceed 0.25% (zero point twenty-five percent) of the value of its assets. For the case of the Voluntary Pension Fund, it shall not exceed the maximum between 1% (one percent) of the value of its assets and the equivalent to 250,000 UI (two hundred fifty thousand indexed units). For these purposes, funds placed in the Central Bank of Uruguay will not be counted.

28. REPLACE in Title III – Custody Companies, of Book II – Stability and solvency, articles 101, 102, 103, and 106 with the following:

ARTICLE 101 (TITLE CUSTODY COMPANIES). The Central Bank of Uruguay, financial intermediation institutions authorized to accept deposits, and those other institutions authorized by the Central Bank may be institutions in charge of the custody of the titles representing the investments of the Pension Savings Fund, the Voluntary Pension Fund, and the Special Reserves. The Pension Savings Fund Administrator shall hire a single institution for the custody service, communicating in advance to this Central Bank about the conditions of the contract and the costs that will be charged to the Pension Savings Fund and the Voluntary Pension Fund.

ARTICLE 102 (VALUES AND DELIVERY TERM). Pension Savings Fund Administrators shall deliver to the companies in charge of custody, all titles representing the Pension Savings Fund, the Voluntary Pension Fund, and the Special Reserves, as well as the corresponding certificates of other permitted investments according to art. 123 of Law No. 16.713 and amendments. Such values shall be delivered, at the latest, on the next business day after the date of settlement of the operation.

ARTICLE 103 (ACCOUNTING OF SECURITIES IN CUSTODY). Custody companies shall account for the securities that constitute the assets of the Pension Savings Fund and the Voluntary Pension Fund, recording movements in a disaggregated manner by instrument.

ARTICLE 106 (CUSTODY OF SECURITIES REPRESENTED BY ACCOUNT ENTRIES). For the purposes of complying with custody procedures for those securities belonging to the assets of the Pension Savings Fund and the Voluntary Pension Fund represented by account entries, whose registration is carried out by an institution different from the one providing the custody service, Pension Savings Fund Administrators shall: a. require the registering institutions of said securities that in the respective Register the limitations of rights expressed below appear: i. that they are at the order of the institution providing the custody service ii. that there will be no changes in ownership without prior consent of the institution providing the custody service. b. prove the ownership of the aforementioned securities before the custodian institution by delivering legitimization certificates, as established by articles 222 and 223 of the Compilation of Rules of the Securities Market. Upon expiration of these certificates, Administrators will have one business day to renew them.

29. REPLACE in Section I – Administration Commission, of Chapter IV – Commissions and life and disability insurance premium, of Title I – Client Relationship, of Book IV – Protection of the user of financial services, article 113 with the following:

ARTICLE 113 (ADMINISTRATION COMMISSION – GENERAL REGIME) Administration commissions will be the only income of the Administrator charged to affiliates, and according to what is provided in article 102 of Law No. 16.713 of September 3, 1995 and amendments, in no case shall the commission to be charged by an Administrator exceed by 20% (twenty percent) the system average commission corresponding to the previous month weighted by the volume of assets under management, nor the maximum value in effect on December 31, 2021. The Central Bank of Uruguay will communicate and publish monthly the maximum permitted commission for contributions accrued in said month and the system average commission based on the information of assets under management and commissions applied in the immediate previous month.

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30. INCORPORATE in Section I – Administration Commission, of Chapter IV – Commissions and premium of the disability and death insurance, of Title I – Client Relations, of Book IV – Protection of the user of financial services, the following article:

ARTICLE 113.1 (ADMINISTRATION COMMISSION – SPECIAL REGIME)

For persons entering the labor market from the entry into force of the Common Pension System, the administration commissions on mandatory savings will be applied on balances during the first 36 (thirty-six) months from the date of entry into the labor market. This commission will be uniform for all new contributors.

For these purposes, the date of entry into the labor market is considered the date of affiliation for the first time to a pension entity. In the case of the Professional University Retirement and Pension Fund, the date of graduation or professional qualification, if applicable, will be taken as the date of entry into the labor market.

The commissions will have a maximum equivalent to 50% (fifty percent) of the lowest commission equivalent on balances resulting from flow-based commissions observed in the 12 (twelve) months prior to the effective date, in accordance with the provisions of the regulations.

The Central Bank of Uruguay will communicate and publish monthly the maximum commission referred to in the special regime.

31. SUBSTITUTE in Section I – Administration Commission, of Chapter IV – Commissions and premium of the disability and death insurance, of Title I – Client Relations, of Book IV – Protection of the user of financial services, articles 114 and 115 with the following:

ARTICLE 114 (AMOUNTS SUBJECT TO CHARGE OF ADMINISTRATION COMMISSION).

The following amounts will be subject to the charge of administration commissions: a. Mandatory contributions in accordance with the provisions of Article 102 of Law No. 16.713 of September 3, 1995. b. Voluntary deposits, as well as other complementary savings procedures, in accordance with the provisions of Title VI of Law No. 16.713 of September 3, 1995 and regulatory norms.

Commissions will be applied uniformly for each type of contribution according to the regime applicable in each case.

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ARTICLE 115 (DEFINITION OF MANDATORY CONTRIBUTIONS).

For the purposes of charging the administration commission, mandatory contributions are understood to be those included in letters A), B) and C) of Article 45 of Law No. 16.713 of September 3, 1995 and its amendments.

32. SUBSTITUTE in Section II – Custody Commission, of Chapter IV – Commissions and premium of the disability and death insurance, of Title I – Client Relations, of Book IV – Protection of the user of financial services, article 118 with the following:

ARTICLE 118 (CUSTODY COMMISSION)

Administrators may monthly transfer to their affiliates the commission for the custody of the titles representing the investments that make up the assets of each Pension Savings Subfund and the Voluntary Pension Fund, prorated based on the balance of the corresponding individual accounts in the Subfund on the last day of the previous month.

The amount must be debited from the individual accounts on the same day that the payment to the custodian institution is made effective by the Administrator.

33. SUBSTITUTE in Section II – Account Statement, of Chapter VII – Information to the affiliate, of Title I – Client Relations, of Book IV – Protection of the user of financial services, article 125 with the following:

ARTICLE 125 (DEFINITION).

The information referred to in Article 100 of Law No. 16.713 of September 3, 1995 and its amendments will be detailed in the Account Statement of the Pension Savings Fund as well as in the Account Statement of the Voluntary Pension Fund according to the referral established by Article 148 of Law No. 20.130 of May 2, 2023.

34. INCORPORATE in Section II – Account Statement, of Chapter VII – Information to the affiliate, of Title I – Client Relations, of Book IV – Protection of the user of financial services, the following article:

ARTICLE 125.1 (ACCOUNT STATEMENT OF THE VOLUNTARY PENSION FUND).

For the Voluntary Pension Fund, an account statement must be prepared considering the provisions of Articles 126, 127 and 129.

The aforementioned Account Statement must be presented according to the model elaborated for such purposes by the Superintendence of Financial Services and must contain the following elements: a. Identification of the Pension Savings Fund Administrator and the reported period.

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b. Identification of the affiliate: account number, name, address, and identity document number. c. Balance of the individual account, on the last day of the month prior to the period to which the information refers, expressed in units, in pesos, and in Reajustable Units. d. Detail of all credit and debit movements, expressed in pesos and in units, balance in units and date of registration, identifying the subaccount and explicitly stating:

• voluntary deposits;
• agreed deposits, disaggregated by depositor;
• administration commissions if applicable;
• any other account movement with its detail. e. Information on the adjustments included in the value of the unit, for the concept of profitability, integration or application of the respective Fluctuation Subfund, application of the Special Reserve or State Guarantee. f. Account balance, at the end of the reference period, expressed in units, in pesos, and in Reajustable Units. g. Information on:
• Annual nominal and real profitability.
• Net real profitability and aggregated net real profitability.
• The values in effect on the last day of the reported period of the following figures: commission of the Pension Savings Fund Administrator; commission bonus, if applicable, and custody commission.

35. SUBSTITUTE in Section II – Account Statement, of Chapter VII – Information to the affiliate, of Title I – Client Relations, of Book IV – Protection of the user of financial services, article 128 with the following:

ARTICLE 128 (ACCOUNT STATEMENT OF THE PENSION SAVINGS FUND).

The Account Statement defined in Article 125 of this Compilation must be presented according to the model elaborated for such purposes by the Superintendence of Financial Services and must contain the following elements: a. Identification of the Pension Savings Fund Administrator and the reported period.

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b. Identification of the affiliate: account number and of the subaccount(s), name, address, and identity document number. c. Balances of the account and of the individual subaccount(s) corresponding to each Pension Savings Subfund, on the last day of the month prior to the period to which the information refers, expressed in units, in pesos, and in Reajustable Units and total balances of the account and of the individual subaccount(s) expressed in pesos and in Reajustable Units. d. For each Pension Savings Subfund, detail of all credit and debit movements, expressed in pesos and in units, balance in units and date of registration, identifying the subaccount and explicitly stating:

• mandatory contributions, disaggregated by company and month of charge;
• monetary sanctions, disaggregated by company and month of charge;
• average commission of the regime and commission of the Administrator;
• commission bonus, if applicable;
• disability and death insurance premiums;
• custody commission;
• any other account movement with its detail. e. Information on the adjustments included in the value of the unit of each Subfund, for the concept of profitability, integration or application of the respective Fluctuation Subfund, application of the Special Reserve or State Guarantee. f. Balances of the account and of the individual subaccount(s) corresponding to each Pension Savings Subfund, at the end of the reference period, expressed in units, in pesos, and in Reajustable Units and total balances of the account and of the individual subaccount(s) expressed in pesos and in Reajustable Units. g. Information on:
• Annual nominal and real profitability of each Subfund and average annual nominal and real profitability of the regime for each Subfund.
• Average profitability rates of the Pension Savings Fund
• Net real profitability and aggregated net real profitability of the Pension Savings Fund. h. In the case of affiliates who are in the special commission regime referred to in item 5) of Article 103 of Law No. 16.713 and its amendments and have less than 36 (thirty-six) months of entry into the system, they must

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present the values in effect on the last day of the reported period of the following figures:

• simple average commission of the regime for each Subfund,
• commission of the Pension Savings Fund Administrator for each Subfund,
• commission bonus if applicable,
• commission applicable for the period after 36 (thirty-six) months, and,
• custody commission.

36. INCORPORATE in Section III – Advice to affiliates, of Chapter VII – Information to the affiliate, of Title I – Client Relations, of Book IV – Protection of the user of financial services, the following article:

ARTICLE 129.1.1 (ADVICE TO AFFILIATES ON MOVEMENTS BETWEEN SUBFUNDS).

Pension Savings Fund Administrators must communicate to their affiliates with an advance of between 3 (three) and 12 (twelve) months when it corresponds to incorporate them into a Subfund different from the one to which their contributions are received, indicating the possibility of choosing to remain in the Subfund for an additional period of between 1 (one) and 5 (five) years.

This information must include as a minimum:

• the comparative information on annual gross real profitability of each Subfund for the last 60 (sixty) months.
• the composition of the investments of each of the Subfunds.

The Administrator must keep the corresponding record of the documentation delivered to the affiliate by means that allow its verification, in accordance with the provisions of Article 144.7.

37. REPEAL in Section III – Advice to affiliates, of Chapter VII – Information to the affiliate, of Title I – Client Relations, of Book IV – Protection of the user of financial services, article 129.2.

38. INCORPORATE in Chapter VIII – Other provisions, of Title I – Client Relations, of Book IV – Protection of the user of financial services, the following article:

ARTICLE 129.4 (TRANSFER BETWEEN SUBFUNDS).

Pension Savings Fund Administrators must make effective the requests for transfers between Subfunds received from their affiliates within a maximum period of 10 (ten) business days counted from the month following the receipt of the aforementioned request.

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39. SUBSTITUTE in Chapter VIII – Other provisions, of Title I – Client Relations, of Book IV – Protection of the user of financial services, article 134 with the following:

ARTICLE 134 (COMMUNICATION TO THE AFFILIATE REGARDING EXCESS CONTRIBUTIONS AND DESTINATION OF FUNDS).

Pension Savings Fund Administrators must communicate to affiliates who generate for the first time funds for the concept of contributions that exceed those legally corresponding based on their computable allocations, the existence of such funds and require the affiliate to respond indicating their decision on the destination to give to all sums that the Administrator receives for that concept. Such communication must be made within the period of 10 (ten) business days of receiving from the Social Security Bank the funds contributed in excess and must include information on the date of receipt of such funds by the Administrator, as well as the period referred to in the final paragraph of this article and the consequence of the absence of response by the affiliate.

The affiliate's response may be obtained through a written and signed record, by telephone, via email, or through the Administrator's web portal. In all cases, the Administrator must establish the necessary procedures to verify that the person exercising the option is indeed the account holder, as well as register such option in a way that allows its verification, in accordance with the provisions of Article 144.7.

If within the term of 30 (thirty) calendar days of receiving the funds from the Social Security Bank, the affiliate does not manifest – by any of the aforementioned means – their will regarding the destination of the excess contribution generated, such sum will be definitively credited to their respective account in the Voluntary Pension Fund. Without prejudice to the foregoing, upon receiving new excess contributions from the same affiliate, the Administrator will make maximum efforts to obtain the affiliate's decision on the destination of the funds. The Administrator must keep records of such efforts, even if they have been unsuccessful.

40. SUBSTITUTE in Section II – Advertising carried out by supervised institutions, of Chapter I – Advertising, of Title I – Transparency of Book V – Transparency and market conduct, articles 142 and 143 with the following:

ARTICLE 142 (INFORMATION TO BE EXHIBITED IN OFFICES).

Pension Savings Fund Administrators must maintain in their offices and website, in a place clearly visible to the public, at least the following written and updated information:

1. Background of the institution, indicating the first and last name of its directors, administrators, managers, and auditors.

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2. Accounting statements of the Administrator of the last fiscal year with External Audit Opinion, balance sheets and quarterly income statements, and the distribution of profits, if any.

3. Value of the assets of each Pension Savings Subfund, value of each Profitability Fluctuation Subfund and value of each Special Reserve, as well as the value of the Voluntary Pension Fund.

4. Composition of the investment portfolio of the assets of each Pension Savings Subfund and the investment portfolio of the Voluntary Pension Fund, as well as the name of the depository institutions of the titles and deposits.

5. Regime and amount of commissions on contributions and on balances, in effect for each Pension Savings Subfund and for the Voluntary Pension Fund. The percentages of administration commission and custody commission must be established in a disaggregated manner, in the form established by the Superintendence of Financial Services. The custody commission to be advertised will be the one corresponding to the last month, expressed as a percentage of the balance of individual accounts.

6. Name of the insurance companies with which the collective disability and death insurance contract has been signed and the percentage of insurance premium paid to them by each Subfund.

7. Name of the authorized insurance companies for the payment of life annuity benefits that are currently offering in that market, together with the information on the initial annuity offered for the concept of common retirement or retirement for advanced age that they pay for each 1,000 (one thousand) Uruguayan pesos of accumulated balance in the affiliate's individual savings account, for ages 60 to 75.

The information referred to in item 7. will be obtained from the internet site of the insurance companies in accordance with the provisions of Article 101.3 of the Compilation of Insurance and Reinsurance Regulations.

The information referred to in items 1. to 7. must be updated monthly, within the first 10 (ten) days of each month, or on the occasion of any event that may significantly alter the content of the information available to the public.

ARTICLE 143 (ADVERTISING OF THE AVERAGE VALUE OF THE UNIT).

Advertising regarding the average value of the unit of each Pension Savings Subfund and the Voluntary Pension Fund for a

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determined month must be based on the value obtained after the adjustments corresponding in compliance with the provisions established by Articles 117, 119, 120 and 122 of Law No. 16.713 of September 3, 1995 and its amendments.

41. REPEAL in Section II – Advertising carried out by supervised institutions, of Chapter I – Advertising, of Title I – Transparency of Book V – Transparency and market conduct, article 143.1.

42. SUBSTITUTE in Chapter I – Accounting and accounting statements, of Title II – Information Regime, of Part I – Pension Savings Fund Administrators, of Book VI – Information and documentation, article 147 with the following:

ARTICLE 147 (SPECIAL RESERVE).

The accounting statements of Pension Savings Fund Administrators must contain a note stating that the balance of the "Special Reserve Investments" asset chapter is non-seizable and corresponds to the item provided for in Article 121 of Law No. 16.713 of September 3, 1995 and its amendments.

43. SUBSTITUTE in Chapter II – External Auditors, of Title II – Information Regime, of Part I – Pension Savings Fund Administrators, of Book VI – Information and documentation, article 148 with the following:

ARTICLE 148 (EXTERNAL AUDITORS' REPORT).

Pension savings fund administrators must present the following reports issued by external auditors:

a. At the close of the annual fiscal year, within a period of 2 (two) months counted from the end of the economic year:

a.1) Opinion on the balance sheet at the close of the annual fiscal year and the income statement corresponding to said period of the Administrator.

a.2) Single opinion on the balance sheet at the close of the annual fiscal year and the income statement corresponding to said period of each Pension Savings Subfund and the Pension Savings Fund.

a.3) Opinion on the Voluntary Pension Fund.

b. Annual report on the accounting system used and its adequacy to the norms and the Chart of Accounts dictated by the Superintendence of Financial Services, and on the concordance with said accounting system, of the statements and other information presented to said Superintendence of Financial Services, whether referred to the Company, each Pension Savings Subfund or the Voluntary Pension Fund, within a

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period of 2 (two) months counted from the end of the economic year.

c. Triennial report on the comprehensive evaluation of the adequate functioning of the integrated risk management system and annual reports on materially significant deficiencies or omissions detected, the recommendations issued to overcome them, and the corrective measures adopted by the institution. The aforementioned reports must be presented within a period of 5 (five) months and 3 (three) months counted from the end of the economic year, respectively.

d. Annual report on the suitability and functioning of the policies and procedures adopted by the Administrator to prevent and detect operations that may be related to money laundering, terrorist financing, and the financing of the proliferation of weapons of mass destruction, and partial reports on their significant deficiencies or omissions, the recommendations issued to overcome them, and a comment on the observations made in the previous exercise that have not been resolved, within a period of 5 (five) months counted from the end of the economic year.

44. SUBSTITUTE in Chapter V BIS – Information to insurance companies and to the Social Security Bank, of Title II – Information Regime, of Part I – Pension Savings Fund Administrators, of Book VI – Information and documentation, article 155.1 with the following:

ARTICLE 155.1 (INFORMATION TO BE SUPPLIED TO INSURANCE COMPANIES REGARDING THE COLLECTIVE DISABILITY AND DEATH INSURANCE).

Pension savings fund administrators must supply to the insurance companies with which they have signed the Collective Disability and Death Insurance contract referred to in Article 57 of Law No. 16.713 of September 3, 1995 and its amendments, monthly information on their affiliates, the contribution salaries for the individual savings regime, and the accumulated savings according to the instructions that will be issued. Such information must be delivered to the insurer within the period stipulated in the contract.

45. INCORPORATE in Chapter V BIS – Information to insurance companies and to the Social Security Bank, of Title II – Information Regime, of Part I – Pension Savings Fund Administrators, of Book VI – Information and documentation, the following article:

ARTICLE 155.1.1 (INFORMATION TO BE SUPPLIED TO INSURANCE COMPANIES REGARDING PENSION INSURANCES).

It is the obligation of the Pension Savings Fund Administrator to provide to the insurance company, regarding pension annuity insurances and the collective disability and death insurance, the information that allows to correctly appreciate the risk that may influence

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36 in the conditions of the contract. Once the event occurs, the necessary background information to prove it and allow its correct settlement must be made available to the insurance company. Regarding the benefit for partial disability, the period during which it must be paid must be indicated. 46. REPEAL in Chapter V TER – Disaffiliations and revocations, of Title II – Information Regime, of Part I – Pension Savings Fund Administrators, of Book VI – Information and Documentation, Articles 155.6 and 155.7. 47. SUBSTITUTE in Chapter VI – Other Information, of Title II – Information Regime, of Part I – Pension Savings Fund Administrators, of Book VI – Information and Documentation, Article 160.5 with the following: ARTICLE 160.5 (INFORMATION ON PLACEMENTS AND PERSONAL LOANS DERIVED FROM PLACEMENTS UNDER LETTER F) OF ARTICLE 123 OF LAW NO. 16.713). Pension Savings Fund Administrators must inform the Financial Services Superintendence, with a minimum advance of 3 (three) business days prior to the integration of the new vouchers corresponding to personal loans derived from placements under letter F) of Article 123 of Law No. 16.713 of September 3, 1995 and its amendments, the following aspects: a. modifications to the conditions (rates and terms) of authorized agreements agreed upon by the parties, respecting the established categories; b. renewals resulting from partial cancellations, identifying:

• the conditions of the original voucher (number, issue date, maturity date, interest rate, and amount).
• the conditions of the new voucher (number, renewal date, maturity date, interest rate, and amount).

48. SUBSTITUTE in Chapter I – Accounting and Financial Statements, of Title I – Information Regime, of Part II – Pension Savings Funds, of Book VI – Information and Documentation, Articles 163 and 163.1 with the following: ARTICLE 163 (ACCOUNTING AND MANAGEMENT INFORMATION). Pension Savings Fund Administrators must provide the Financial Services Superintendence with the following information referred to each Pension Savings Subfund, the Pension Savings Fund, and the Voluntary Pension Fund, in accordance with the instructions to be issued, at the frequency indicated below: Diagonal Fabini 777 - C.P. 11100 - Tel.: (598 2) 1967 - Montevideo, Uruguay - www.bcu.gub.uy CIRCULAR NO. 2438

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1. Annually: Within a period of 2 (two) months counted from the end of the fiscal year: a) Annual balance sheet of each Pension Savings Subfund together with its corresponding explanatory notes, annexes, and statement of changes in equity. b) Annual balance sheet of the total Pension Savings Fund. c) Annual balance sheet of the Voluntary Pension Fund together with its corresponding explanatory notes, annexes, and statement of changes in equity.
2. Monthly: Within a period of 10 (ten) business days following the period to which they refer: a) Monthly balance sheet of each Pension Savings Subfund together with its corresponding explanatory notes, annexes, and statement of changes in equity. b) Monthly balance sheet of the total Pension Savings Fund. c) Monthly balance sheet of the Voluntary Pension Fund together with its corresponding explanatory notes, annexes, and statement of changes in equity. ARTICLE 163.1 (PUBLIC ACCOUNTANT'S REPORT). Pension Savings Fund Administrators must present the monthly balance sheet of each Pension Savings Subfund, the Pension Savings Fund, and the Voluntary Pension Fund accompanied by a compilation report prepared in accordance with Pronouncement No. 18 of the College of Accountants, Economists, and Administrators of Uruguay, which will include the affiliation number to the Retirement and Pension Fund for University Professionals of the Public Accountant who signs the aforementioned report. Submission will be made to the Financial Services Superintendence within 24 (twenty-four) hours following the expiration of the deadline for presenting the respective information.
3. REPEAL in Chapter II – External Auditors, of Title I – Information Regime, of Part II – Pension Savings Funds, of Book VI – Information and Documentation, Article 164.1. Diagonal Fabini 777 - C.P. 11100 - Tel.: (598 2) 1967 - Montevideo, Uruguay - www.bcu.gub.uy CIRCULAR NO. 2438

38 50. SUBSTITUTE in Chapter III – Profitability, of Title I – Information Regime, of Part II – Pension Savings Funds, of Book VI – Information and Documentation, Article 164.3 with the following: ARTICLE 164.3 (INFORMATION FOR THE CALCULATION OF GROSS PROFITABILITY). Pension Savings Fund Administrators must provide the Financial Services Superintendence, in accordance with the instructions to be issued, monthly information for the purpose of verifying the calculations of the gross profitability of each Pension Savings Subfund and the Voluntary Pension Fund on the first business day following the month being reported. 51. SUBSTITUTE in Chapter IV – Assets and Investments, of Title I – Information Regime, of Part II – Pension Savings Funds, of Book VI – Information and Documentation, Articles 164.4 and 164.5 with the following: ARTICLE 164.4 (INFORMATION ON ASSETS). Pension Savings Fund Administrators must provide the Financial Services Superintendence, in accordance with the instructions to be issued, daily information on the movements of the assets of each Pension Savings Subfund and the Voluntary Pension Fund, as well as the movements of shares of each Subfund and the Voluntary Pension Fund, on the first business day following the one to which it refers. ARTICLE 164.5 (INFORMATION ON INVESTMENTS). Pension Savings Fund Administrators must provide the Financial Services Superintendence, in accordance with the instructions to be issued, daily information on the investments that make up the assets of each Pension Savings Subfund and the Voluntary Pension Fund, on the first business day following the one to which it refers. 52. EFFECTIVE DATE. The provisions set forth in items 1 to 51 shall be effective as of December 1, 2023. JUAN PEDRO CANTERA Superintendent of Financial Services 2023-50-1-01182 Diagonal Fabini 777 - C.P. 11100 - Tel.: (598 2) 1967 - Montevideo, Uruguay - www.bcu.gub.uy CIRCULAR NO. 2438