Deputy Superintendent Resolution No. 012-2025-SMV/11

PERÚ Ministry of Economy and Finance

SMV
Securities Market
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 Deputy Superintendent Resolution SMV No. 012-2025-SMV/11 Lima, February 5, 2025 Subject: Sanction PANORO MINERALS LTD with a total fine of 10 UIT, for having committed one (01) serious offense type in item 2.10 of numeral 2 of Annex I of the Sanctions Regulation. Regulated Entity: PANORO MINERALS LTD. Subject: Administrative Sanctioning Procedure with double administrative instance Main Type: Item 2.10 of numeral 2 of Annex I of the Sanctions Regulation SERIOUS OFFENSE File No.: 2024042471 The Deputy Superintendent of Market Conduct Supervision VIEWED:
The administrative file No. 2024042471 containing the administrative sanctioning procedure (hereinafter, the PAS) initiated by the General Superintendent of Conduct Compliance of the Securities Market Superintendency – SMV (hereinafter, the IGCC), against PANORO MINERALS LTD (hereinafter, the Issuer); as well as Report No. 1617-2024-SMV/11.2 (hereinafter, the Report), issued by the IGCC; CONSIDERING:
I. FUNCTION AND COMPETENCE OF THE SASCM

1. That, the IGCC –instructor body of the PAS referred to in
   this case–, has brought to the knowledge of the Deputy Superintendent of Market Conduct Supervision of the SMV (hereinafter, SASCM), the PAS of administrative file No. 2024042471 with the aim that it issues a decision as sanctioning body of first instance in said PAS. In this way, the SASCM

PERÚ Ministry of Economy and Finance

SMV
Securities Market
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 assumes competence in observance of the exercise of the supervision function and of the sanctioning faculty of the SMV established through the Unified Concordant Text of its Organic Law, Decree Law No. 26126 (hereinafter, LOSMV), and the Unified Ordered Text of the Securities Market Law, Legislative Decree No. 861, approved by Supreme Decree No. 020-2023-EF-1 (hereinafter, TUO of the LMV); as well as by what is provided in the Sanctions Regulation, approved by SMV Resolution No. 035-2018- SMV/01 (hereinafter, Sanctions Regulation); and, in articles 42 and 43 of the Regulation of Organization and Functions of the SMV, approved by Supreme Decree No. 216-2011-EF (hereinafter, ROF-SMV), in the sense that it is a specific function of the SASCM, to impose sanctions in first administrative instance for the commission of infractions whose compliance control corresponds to the referred Deputy Superintendency. Likewise; the SASCM has the faculties to issue corrective measures aimed at reversing the situation altered by the commission of the infraction;
2. That, the present PAS corresponds to two (2)
administrative instances in accordance with the first paragraph of article 14 of the Sanctions Regulation and numeral 13 of article 43 of the ROF-SMV, which establish that, among others, it is a specific function of the Deputy Superintendent of the SASCM, to impose sanctions in first administrative instance for the commission of infractions whose compliance control corresponds to the SASCM. Complementary to this, in accordance with article 15 of the Sanctions Regulation and numeral 26 of article 12 of the ROF-SMV, the Superintendent of the Securities Market resolves the appeals against the resolutions issued in first instance by the Deputy Superintendent of the SASCM, with the exception of single-instance procedures;
II. FACTS, CHARGES AND DEFENSES
2.1 Facts
3. That, it was evaluated whether the Issuer complied or not with disclosing
to the securities market the material fact referred to the suspension of the trading of the Issuer's common shares on the TSXV Venture Exchange – TSXV (origin market), ordered by the “Investment Industry Regulatory Organization of Canada - IIROC” on October 12, 2021;
4. That, regarding this, through letter EMI-491/2021 of
October 12, 2021, the Lima Stock Exchange (BVL) informed the Issuer that, on that date, it had proceeded to the suspension of trading in the Stock Exchange Round of its common shares, and that said suspension was carried out having taken knowledge of the suspension of the trading of said securities ordered in Canada by the IIROC. Likewise, the BVL requested the Issuer to comply with informing as a material fact to the Peruvian market the suspension of the trading of its securities in its market of origin and in the Stock Exchange Round, as well as, to inform on the occasion when it occurs, the lifting of said suspension;
5. That, through letter EMI-534/2021 of October 28
2021, the BVL reiterated to the Issuer that the information regarding the suspension of the trading of Panoro shares on the TSXV from October 12, 2021, resumed on October 13, 2021 constitutes a material fact that it should have

PERÚ Ministry of Economy and Finance

SMV
Securities Market
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 inform to the market;
2.2 Charge
6. That, from the verification of the control records
regarding the submission of information to the Public Registry of the Securities Market — RPMV, it was verified that the Issuer would not have complied with communicating as a material fact the suspension ordered by IIROC of the trading of the Issuer's common shares on the TSXV, which occurred on October 12, 2021, which should have been communicated on the same day; however, it has not been communicated to date;
2.3 Defenses
7. That, the Issuer has not sent the corresponding
defenses to the charge formulated despite being validly notified;
8. That, regarding this matter, it is necessary to indicate that the
Issuer was validly notified with the Charge Office on October 23, 2024 via the MVNet System, as verified from the receipt acknowledgment that is in the log of the MVNet System, in application of what is established in article 37 1 of the Regulation of the MVNet and SMV Virtual System, approved by SMV Resolution No. 004-2024- SMV/01 (hereinafter, MVNet Regulation), which states that the notification takes legal effect at the time it is recorded as having been received by the Issuer, according to the date and time registered in the acknowledgment receipt certificate self-generated by the SMV Virtual. Likewise, the norm provides that if the regulated entity does not access the message deposited in the Electronic Mailbox within five (05) business days from the Electronic Notification being made, it will take legal effect from the next business day after the expiration of this period;
9. That, through Supreme Decree No. 004-2019-JUS,
the Unified Ordered Text of Law No. 27444, General Administrative Procedure Law (hereinafter, TUO of the LPAG), was approved, which contains common norms for the actions of the administrative function of the State and regulates all administrative procedures developed in the entities, including the special procedures. Likewise, numeral 3) of article 248 of the TUO of the LPAG, indicates the criteria regarding the graduation of the sanction: (a) The illicit benefit

1 “Article 37.- Moment and efficacy of Notifications
37.1 The Electronic Notification procedure is initiated by the SMV with the deposit of the administrative act or administrative action in the Electronic Mailbox of the Users of the SMV Virtual. The
SMV Virtual automatically generates the Electronic Notification Certificate. Likewise, the SMV communicates to the email and cell phone of the Users of the SMV Virtual, the data of the notification validly made.
37.2 The Users of the SMV Virtual must carry out the confirmation of receipt through the Certificate
of Acknowledgment of Receipt during the five (05) first business days following the validly made notification. The Electronic Notification takes legal effect at the time it is recorded as having been received by the User of the SMV Virtual, according to the date and time registered in the Certificate of Acknowledgment of Receipt self-generated by the SMV Virtual.
37.3 However, if the User of the SMV Virtual does not access the message deposited in their Electronic Mailbox within a period of five (05) business days from the Electronic Notification being made, it takes
legal effect from the next business day after the expiration of this period.
37.4 Exceptionally, as determined by the organs or organizational units of the SMV, acts or administrative actions can be notified in cases that require greater speed in the processing of the notification, through personal notification, in addition to the notification via electronic mailbox. In these cases, the notification that first proves effective will prevail, according to law.”
(Underline added).

PERÚ Ministry of Economy and Finance

SMV
Securities Market
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 resulting from the commission of the infraction, (b) The probability of detection of the infraction, (c) The gravity of the damage to the public interest and/or protected legal good, (d) The economic damage caused, (e) Recidivism, for the commission of the same infraction within the period of one (1) year from when the resolution sanctioning the first infraction became final, (f) The circumstances of the commission of the infraction and, (g) The existence or not of intentionality in the conduct of the infringer;
10. That, the charges formulated and the criteria regarding
the graduation of the sanction have been the subject of evaluation in the Report, which has been submitted to the knowledge of the SASCM;
11. That, in observance of what is established by numeral
5 of article 255 of the TUO of the LPAG, through Office No. 5821-2024-SMV/11 of December 23 2024, the Report was sent to the Issuer so that it formulates its allegations within the period of five (05) business days; however, despite being legally notified via the MVNet System in accordance with the MVNet Regulation, to date, it has not presented them;
III. MATTERS TO BE DETERMINED
12. That, in the present PAS it corresponds to determine the
following:
(i) Whether the Issuer incurred or not in the infraction indicated in the Charge Office and Report; (ii) Whether it corresponds or not to impose a sanction on the Issuer;
IV. ANALYSIS
4.1 Applicable Normativity
13. That, article 30 of the TUO of the LMV establishes: “The
registration of a certain security or issuance program entails for its issuer the obligation to inform the SMV and, if applicable, to the respective stock exchange or entity responsible for the conduct of the centralized mechanism, of the material facts, including ongoing negotiations, about itself, the security and the offer that is made of it, as well as to disclose such facts in a true, sufficient and timely manner. (…)”. (Underline added);
14. That, regarding Junior companies included in
the Junior II category, article 7, third paragraph, of the Regulation of the Risk Capital Segment of the Lima Stock Exchange, approved by CONASEV Resolution No. 026-2005-EF/94.10 and its amendments (hereinafter, SCR Regulation), provides the following:
“Article 7.- Registration of common shares with voting rights of Junior Companies included in the Junior II category For the purpose of obtaining the registration of common shares with voting rights in the RBVL, previously issued and placed in a foreign market, the Junior II Company must comply with the following:
(…)
During the validity of the security registration, the Junior II Company must comply with diffuse to the general public, the information it presents in the stock exchanges or organized foreign markets where the security is registered or admitted to

PERÚ Ministry of Economy and Finance

SMV
Securities Market
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 trading, at the same time it presents the information in such markets. Such information will be diffused via internet, information providers (vendors) or by other similar communication means; likewise, the BVL will facilitate access (electronic link) to the public information system, through which the junior company diffuses its information in its main market. The SMV or the BVL may request clarifications, precision or expansions regarding the information diffused and/or the situation of the trading of the securities in its main market. Without prejudice to the diffusion mentioned above, the Junior II Company is obliged to communicate as a material fact, in accordance with what is established in the Regulation of Material Facts and Confidential Information, only the following information:
1. Decision to exclude its shares from the RBVL;
2. Suspension or cessation of functions of its sponsor, as well as the appointment of a
new sponsor;
3. Suspension of the trading of the securities in the market of origin;
4. The sanctions that would have been imposed on the Junior II Company in its market of
origin.
(…)” (Underline added).
15. That, regarding the opportunity to inform about
material facts, numeral 9.1 of article 9 of the Regulation of Material Facts and Confidential Information, approved by SMV Resolution No. 005-2014- SMV/01 (hereinafter, Regulation of Material Facts), states: “The Issuer must inform its material fact as soon as such fact occurs or the Issuer takes knowledge of it, and in no case later than the day on which it has occurred or has been known. (…)”. (Underline added);
16. That, regarding the opportunity to inform about
material facts, numeral 9.1 of article 9 of the Regulation of Material Facts, states: “The Issuer must inform its material fact as soon as such fact occurs or the Issuer takes knowledge of it, and in no case later than the day on which it has occurred or has been known (…)”. (Underline added);
17. That, for the purpose of determining the possible sanction,
this infraction is classified as a serious infraction in item 2.10 of numeral 2 of Annex I of the Sanctions Regulation, which establishes as an infraction:
“Not communicating material facts or not presenting individual or consolidated audited financial statements, individual or consolidated interim financial statements, management report or special audit report and annual reports.” (Underline added);
18. That, in accordance with article 34 of the Sanctions
Regulation, such infractions are sanctionable with a fine not less than twenty-five (25) UIT and up to fifty (50) UIT, or suspension of the trading of securities for up to one (1) year.
4.2 Evaluation of the case
19. That, in the administrative file No.
2024042471, which contains the documentation of the present PAS, it is appreciated that through Report No. 1246-2024-SMV/11.1 of September 23, 2024 (File No.

PERÚ Ministry of Economy and Finance

SMV
Securities Market
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 2024039951), the General Superintendent of Conduct Supervision (hereinafter, IGSC) —organ of the SMV that has within its functions and faculties, the supervision of the compliance of the norms applicable to issuer companies with securities registered in the RPMV, evaluating the indications of possible infractions, and sends, for its consideration, the reports of indications of infractions respectively, to the IGCC—, sent to the IGCC, the result of its evaluation, and specifically what refers to the present case.
20. That, it must be kept in mind that the
procedures and legal forms with which the IGSC conducts its inspection and/or supervision activity and upon concluding it with a report of indications of infraction, determine that its pronouncement or opinion on a specific supervision topic—which even can contain a decision, such as, for example, the adoption of corrective measures—, is an opinion on the merits of the matter; it must be specified that said opinion and the report of indications of infraction of the IGSC, is not binding for the IGCC, as established in the second paragraph of article 9 of the Sanctions Regulation 2 3 ;
21. That, in this way it is had that in the evaluation of
the facts related to the present PAS have intervened and participated previously to the issuance of the present resolution, two other (02) organs of the SMV, functionally independent from each other and from this Office; first the IGSC that on its occasion reported the indications of infraction and then the IGCC that, as a result of its evaluation, formulated the Charge Office and the Report; and at this point of the PAS it corresponds to the Office of the SASCM, to issue a pronouncement containing its decision regarding the charges mentioned, it being precise to indicate that by the nature of the same, as previously indicated, it will be a decision of first administrative instance;
22. That, in that sense, with respect to the non-compliance
detailed in the Charge Office, it proceeds with the evaluation of the imputed infraction;
23. That, previously it is necessary to indicate that the

2 In article 245 of the TUO of the LPAG it is indicated as forms or modes in which the activity of inspection could be concluded the following: 1) Certificate of conformity of the activity developed by the regulated entity; 2) Recommendation of improvements or corrections of the activity developed by the regulated entity; 3) The warning of the existence of non-compliances not susceptible of merit the determination of administrative responsibilities; 4) The recommendation of the initiation of a procedure with the aim of determining the administrative responsibilities that correspond; 5) The adoption of corrective measures and 6) Other forms as established by special laws. 3 Article 9.- PRELIMINARY INQUIRIES AS A CONSEQUENCE OF SUPERVISION ACTIONS (…) When said organs conclude that there are sufficient indications of possible infractions administrative infractions they send the corresponding reports to the General Superintendencies of Compliance, which determine if it corresponds to initiate or not an administrative sanctioning procedure. If so, the General Superintendencies of Compliance may carry out additional inspections or investigations of the reported indications. In the case of possible infractions in the scope of the Regulation of the Participatory Financing Activity and its Managing Societies, the preliminary inquiries are carried out by the General Superintendent of Investigation and Innovation, a dependency that if there are sufficient indications of possible infractions administrative infractions will determine if it corresponds to initiate or not an administrative sanctioning procedure. (…).

PERÚ Ministry of Economy and Finance

SMV
Superintendencia del Mercado de Valores
“Decenio de la Igualdad de Oportunidades para Mujeres y Hombres” "Año de la recuperación y consolidación de la economía peruana" Electronically signed document in 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 The Issuer is a company incorporated under the laws of the province of Vancouver – Canada, with common shares with voting rights listed on the TSXV, as well as on the Frankfurt Stock Exchange. Likewise, through Issuers Directorial Resolution No. 004-2007-EF/94.06.3 of May 11, 2007, the registration of the common shares with voting rights representing the social capital of the Issuer in the RPMV, under the category of Junior II mining company, as well as its listing in the Register of Securities of the Lima Stock Exchange – RBVL, was ordered;
24. That, in that sense, in accordance with what is provided in article 7, third paragraph, of the SCR Regulation, the Issuer has the obligation to communicate as a material event, among others, the suspension of the trading of its securities in the market of origin;
25. That, regarding this matter, the IGSC brought to the knowledge of this General Superintendency that from the review of the notifications and bulletins of the Issuer published through the portal www.apps.tmx.com 45, it was observed that on October 12, 2021, the IIROC, the regulatory body of said market, suspended the trading of the Issuer's common shares on the TSXV; as well as that on October 13, 2021, the suspension on the TSXV was lifted;
26. That, regarding this, as already mentioned, the BVL through letter EMI-491/2021 of October 12, 2021 informed the Issuer that, on that date, the trading suspension in the Bolsa Rueda of its common shares had been proceeded, and that said suspension was carried out having taken knowledge of the suspension of the trading of said values ordered in Canada by the IIROC. Likewise, the BVL requested the Issuer to comply with informing as a material event to the Peruvian market the suspension of the trading of its values in its market of origin and in the Bolsa Rueda, as well as, to inform on the opportunity when the lifting of said suspension occurs;
27. That, likewise, through letter EMI-534/2021 of October 28, 2021, the BVL reiterated to the Issuer that the information regarding the suspension of the trading of its shares on the TSXV of October 12, 2021 resumed on October 13, 2021 constitutes a material event that it should have complied with informing the market;
28. That, however, as of the date of preparation of the Report, the Issuer has not yet complied with correcting said omission to disclose as a material event the suspension of its values in its market of origin and in the Bolsa Rueda carried out on October 12, 2021 and resumed on October 13, 2021;
29. That, consequently, the conduct constituting an infringement by the Issuer has been proven and administrative responsibility is determined, for which reason, it corresponds to analyze the sanction proposal attending what is provided by the principle of reasonableness and to the sanction criteria, which will be evaluated in the subsection of Determination of the Sanction;
V. DETERMINATION OF THE SANCTION

4 https://money.tmx.com/en/quote/PML/news/6893047474464867/IIROC_Trading_Halt_PML https://money.tmx.com/quote/PML/news/8417737176528215/IIROC_Trading_Resumption_PML

PERÚ Ministry of Economy and Finance

SMV
Superintendencia del Mercado de Valores
“Decenio de la Igualdad de Oportunidades para Mujeres y Hombres” "Año de la recuperación y consolidación de la economía peruana" Electronically signed document in 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
30. That, for the purpose of determining the possible sanction, it must be pointed out that in accordance with what is provided in subsection 2.10 of numeral 2 of Annex I of the Sanctions Regulation, it constitutes a serious infringement: “Not communicating material events or not presenting individual or consolidated audited financial information, individual or consolidated interim financial statements, management report or special audit report and annual memoranda.” (highlighting and underlining added);
31. That, in accordance with article 34 of the Sanctions Regulation, said infringements are sanctionable with a fine of not less than twenty-five (25) UIT and up to fifty (50) UIT, or suspension of the trading of securities for up to one (01) year;
SANCTION CRITERIA
32. That, having determined the commission of the imputed infringement, it corresponds to determine the sanction in accordance with article 25 of the Sanctions Regulation, concordant with numeral 3) of article 248 of the TUO of the LPAG and article 344 of the TUO of the LMV, which develop the following sanction graduation criteria: (i) the sanction antecedents of the issuer, (ii) recidivism, (iii) the circumstances of the commission of the infringement, (iv) the economic damage caused and its repercussion on the market, (v) the illicit benefit resulting from the commission of the infringement, (vi) the probability of detection of the infringement, (vii) the gravity of the damage to the public interest and/or protected legal good and (viii) the existence or not of intent in the conduct of the infringer;
33. That, regarding the criterion of gravity of the damage to the public interest and/or protected legal good, it must be indicated that the presentation of periodic or eventual information by issuers of securities registered in the RPMV constitutes a fundamental obligation in the transparency of the securities market, so that market participants can make their investment decisions adequately informed. Consequently, although no gravity of damage to the public interest is evidenced, the non-compliance with the obligation to inform the market within the deadline limits by the issuers affects the transparency of the market, which is considered a protected legal good;
34. That, regarding sanction antecedents, subsection a) of article 25 of the Sanctions Regulation establishes that they are the firm sanctions imposed by the SMV within the period of four (4) years prior to the commission of the infringement to be sanctioned; without prejudice to this, it is specified that the commission of the same infringement in the year prior to the infringement to be sanctioned is not considered as an antecedent. Regarding this, from the verification carried out in the SMV Sanctions System, it has been determined that the Issuer has sanction antecedents, as detailed in the Report;
35. That, regarding recidivism for the commission of the same infringement, subsection b) of article 25 of the Sanctions Regulation establishes that it takes into account that firm sanction imposed by the SMV within the period of one (01) year prior to the commission of the infringement to be sanctioned. Regarding this, it has been verified that there is no recidivism on the part of the Issuer;
36. That, regarding the circumstances of the commission of the infringements, it must be pointed out that, from the review of the control records regarding the presentation of information to the RPMV and of the section of material events of the SMV Institutional Page on the Digital Unified Platform of the Peruvian State for Citizen Orientation 6, it has been verified that as of the date the Issuer has not complied with communicating as a material event the suspension of the trading of the Issuer's common shares on the TSXVE, which occurred on October 12, 2021; it must be warned that the referred suspension of the trading of the Issuer's common shares was only for one (01) day, resuming on October 13, 2021. In the same line, it must be mentioned that, as of the date, there has been no claim or complaint by any shareholder and/or investor against the Issuer related to the non-compliance subject of the charge;
37. That, regarding the existence of the economic damage caused and its repercussion on the market, it is considered that although it has not been evidenced that the Issuer's non-compliance has produced a quantifiable damage, understood as an economic damage caused to one or several investors. Nevertheless, we consider that there is a damage that impacts the market because the failure to disseminate relevant information such as the suspension of the trading of the Issuer's common shares in a timely manner, produces an impact on the transparency of the securities market, which is considered a protected legal good;
38. That, regarding the illegally obtained benefit, in the present case, there are not sufficient elements to indicate that the Issuer obtained an illegal benefit as a consequence of the commission of the infringement under evaluation;
39. That, regarding the criterion of probability of detection of the infringement, it must be pointed out that the failure to present periodic or eventual information in a timely manner is verified through internal control systems, so the probability of detection is high;
40. That, regarding the existence or not of intent in the conduct of the infringer, it can be pointed out that there are not sufficient elements to indicate that the Issuer acted with intent in the commission of the infringement, so this criterion would not have been configured. However, it is necessary to indicate that despite there being no indications to state that the Issuer acted with intent, it can be affirmed that the conduct of the Issuer was negligent, by not acting with the diligence required before obligations already known by the Issuer;
APPLICATION OF SANCTION CORRESPONDING TO A CLASSIFICATION LOWER THAN PREVIEW
41. That, according to the charge formulated, the Issuer has incurred a serious nature infringement, whose fine corresponds between twenty-five (25) and fifty (50); however, according to the principle of reasonableness, it would be applicable what is provided by the last paragraph of article 25 of the Sanctions Regulation, which states that: “When, from the evaluation of the aforementioned criteria, it is observed that there is no proportionality between the sanction to be imposed and the imputed facts, by exception and through a reasoned resolution, a sanction corresponding to a classification lower than the provided for can be imposed.”,

6 Link of the SMV Institutional Page on the Digital Unified Platform of the Peruvian State for Citizen Orientation: https://www.gob.pe/smv

PERÚ Ministry of Economy and Finance

SMV
Superintendencia del Mercado de Valores
“Decenio de la Igualdad de Oportunidades para Mujeres y Hombres” "Año de la recuperación y consolidación de la economía peruana" Electronically signed document in 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 for the following considerations: i) the suspension of the trading of the Issuer's common shares was only for one (01) day, resuming the next day in the market of origin and in the securities exchange of Peru; ii) as of the date there has been no claim or complaint by any shareholder and/or investor against the Issuer, so it can be affirmed that it has not been evidenced that the non-compliance has produced a quantifiable damage, understood as an economic damage caused to one or several investors; iii) although the Issuer has sanction antecedents, it has not been evidenced that by the non-compliance evaluated in the present PAS it has obtained a benefit for its illegal conduct, nor has it been accredited that it acted with intent;
42. That, in attention to what was previously stated, this Adjunct Superintendency considers that by exception, it is applicable a sanction corresponding to a classification lower than the provided for, that is, imposing a sanction corresponding to minor infringements;
43. That, in conformity with the evaluation carried out in the present PAS, considering the Sanction Criteria and the analysis carried out by this Adjunct Superintendency, it corresponds to impose on the Issuer as a sanction a fine of 10 UIT 7 equivalent to S/ 44,400.00 (Forty-Four Thousand Four Hundred and 00/100 Soles);
44. That, finally, being to what is provided in numerals 13 and 36 of article 43 of the Regulation of Organization and Functions of the SMV, approved by Supreme Decree No. 216-2011-EF;
RESOLVES:
Article 1º.- Declare that PANORO MINERALS LTD has incurred a serious nature infringement, typified in subsection 2.10 of numeral 2 of Annex I of the Sanctions Regulation, approved by SMV Resolution No. 035-2018-SMV/01, for the omission in the communication of the material event referred to the suspension of the trading of the common shares of the Issuer on the TSXV Venture Exchange – TSXV (market of origin), ordered by the “Investment Industry Regulatory Organization of Canada - IIROC” on October 12, 2021.
Article 2º.- Sanction PANORO MINERALS LTD, with a fine of 10 UIT equivalent to S/ 44,400.00 (forty-four thousand four hundred and 00/100 Soles) for what is provided in the preceding article of this Resolution.
Article 3º.- This Resolution does not exhaust the administrative route, this being able to be challenged before this Adjunct Superintendency of Market Conduct Supervision through the filing of the reconsideration or appeal resource, administrative resources recognized in article 218 of the Single Text of the Law No. 27444, Law of the General Administrative Procedure, approved by Supreme Decree No. 004-2019-JUS and its amendments, within the period of fifteen (15) business days, counted from the day following its notification, for being a procedure of double administrative instance. In case the present Resolution is not challenged, the regime of reduction of the corresponding sanction can be accepted.

7 The Supreme Decree No. 392-2020-EF fixed the UIT for the 2021 exercise at S/ 4,400.00.

PERÚ Ministry of Economy and Finance

SMV
Superintendencia del Mercado de Valores
“Decenio de la Igualdad de Oportunidades para Mujeres y Hombres” "Año de la recuperación y consolidación de la economía peruana" Electronically signed document in 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
Article 4º.- Order the diffusion —through the “SMV Institutional Page on the Digital Unified Platform of the Peruvian State for Citizen Orientation (www.gob.pe/smv)”, in the corresponding section—of the present Resolution issued by the Adjunct Superintendency of Market Conduct Supervision, decision-making body of the first administrative instance, in accordance with what is provided by article 5 concordant with numeral 14 of article 7 of the “Policy on diffusion of normative projects, general character legal norms, early agenda and other administrative acts of the SMV”, approved by SMV Resolution No. 014-2014-SMV/01 and its amendments, independently of that it can be subject of challenge.
Article 5º.- Transcribe the present Resolution to PANORO MINERALS LTD.
Register, communicate and publish.
Carlos Rivero Zevallos
Adjunct Superintendent
Adjunct Superintendency of Market Conduct Supervision