General Superintendent of Conduct Supervision Resolution No. 065-2025-SMV/11.1

PERÚ Ministry of Economy and Finance

SMV
Securities Market
Superintendence

"Decade of Equal Opportunities for Women and Men" "Year of recovery and consolidation of the Peruvian economy" 1 Electronically signed document under the framework of Law No. 27269, Law on Digital Signatures and Certificates, its regulations and amendments. The integrity of the document and the authorship of the signature(s) can be verified at https://apps.firmaperu.gob.pe/web/validador.xhtml General Superintendent of SMV Resolution No. 065-2025-SMV/11.1 Lima, November 27, 2025 The General Superintendent of Conduct Supervision Seen:
File No. 2025046638, as well as Internal Report No. 1727-2025-SMV/11.1, from the General Superintendent of Conduct Supervision of the Deputy Superintendence of Market Conduct Supervision. Considering:
That, through writings dated October 27 and November 20 of 2025, Empresa de Crédito Vívela S.A. requested the Securities Market Superintendence – SMV, within the framework of the regime applicable to the Market of Institutional Investors, the registration of the issuance program named "First Program of Subordinated Bonds of Vívela", up to a maximum issuance amount of S/ 20,000,000.00 (Twenty Million and 00/100 Soles), and the registration of the respective Master Prospectus in the "Market of Institutional Investors" section of the Public Registry of the Securities Market – RPMV; That, in the documentation and information presented as support for the request to which this resolution refers, it is appreciated that, within the framework of the agreement adopted in the General Shareholders' Meeting of Empresa de Crédito Vívela S.A. of March 26, 2018 and its supplementary General Shareholders' Meeting of March 16, 2023, in the Board of Directors session of the company on March 20, 2024, the characteristics and conditions of the "First Program of Subordinated Bonds of Vívela" were approved, and the gentlemen Roberto Carlos Baba Yamamoto and Marco Antonio Gerardo González Aguayo were granted the necessary powers so that, acting jointly, they can determine the terms, characteristics and other conditions of the referenced issuance program and its issuances; That, through SBS Resolution No. 03184-2025 of September 05 of 2025, the Superintendence of Banks, Insurance and Private Pension Fund Administrators – SBS resolved to give a favorable opinion so that Empresa de Crédito Vívela S.A. carries out the issuance of redeemable subordinated bonds, computable as effective level 2 equity, through the "First Program of Subordinated Bonds of Vívela", up to an amount of S/ 20,000,000.00 (Twenty Million and 00/100 Soles);

PERÚ Ministry of Economy and Finance

SMV
Securities Market
Superintendence

"Decade of Equal Opportunities for Women and Men" "Year of recovery and consolidation of the Peruvian economy" 2 Electronically signed document under the framework of Law No. 27269, Law on Digital Signatures and Certificates, its regulations and amendments. The integrity of the document and the authorship of the signature(s) can be verified at https://apps.firmaperu.gob.pe/web/validador.xhtml That, in accordance with what is established by article 6 of the Regulation of the Market of Institutional Investors, approved by SMV Resolution No. 021-2013-SMV/01 and its modifying norms, the competence of the SMV in the registration procedure of a public offer directed exclusively to institutional investors who are under the regime of the aforementioned regulation, as well as of the respective program and securities, is limited solely to the verification of the presentation of the documentation or requirements established in the Regulation of the Market of Institutional Investors; without this implying a pronouncement or validation regarding the content of the documentation or a certification on the quality, the solvency of the issuer, nor on the risks of the security, of the offer or of the program; That, in this sense, from the evaluation carried out on the documentation presented by Empresa de Crédito Vívela S.A., within the framework of its request, it has been verified that on November 26, 2025 said entity has complied with presenting the requirements established in article 8 of the Regulation of the Market of Institutional Investors for the offers indicated in article 2, numeral 2.1, of the cited regulation; That, article 7, numeral 6, of the Policy on Dissemination 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 modifying norms, establishes that the decisions contained in administrative resolutions referred to the registration of issuance programs and securities within the framework of an advance procedure, as well as the registration of the prospectuses informative, in the Public Registry of the Securities Market, must be subject to dissemination through the SMV Institutional Website on the Digital Platform Unique of the Peruvian State for Citizen Orientation (www.gob.pe/smv); and, Being in accordance with what is established by article 1 of the Law of Promotion of the Securities Market, Law No. 30050; articles 2, 7, 8 and 10 of the Regulation of the Market of Institutional Investors; as well as by article 46, numeral 4, of the Regulation of Organization and Functions of the Securities Market Superintendence, approved by Supreme Decree No. 216-2011-EF, which authorizes the General Superintendent of Conduct Supervision to resolve the requests formulated by the regulated entities linked to primary public offers and evaluate and/or resolve any procedure linked to said offers. Resolves:
Article 1°.- To dispose, within the framework of an advance
procedure, the registration of the issuance program named "First Program of Subordinated Bonds of Vívela", up to a maximum issuance amount of S/ 20,000,000.00 (Twenty Million and 00/100 Soles), and the registration of the Master Prospectus corresponding in the "Market of Institutional Investors" section of the Public Registry of the Securities Market – RPMV.
Article 2°.- The issuances and/or offers that are
carried out by virtue of the registration referred to in article 1° of this resolution, in accordance with what is established in article 11, numeral 11.2, of the Regulation of the Market of Institutional Investors, may be carried out

PERÚ Ministry of Economy and Finance

SMV
Securities Market
Superintendence

"Decade of Equal Opportunities for Women and Men" "Year of recovery and consolidation of the Peruvian economy" 3 Electronically signed document under the framework of Law No. 27269, Law on Digital Signatures and Certificates, its regulations and amendments. The integrity of the document and the authorship of the signature(s) can be verified at https://apps.firmaperu.gob.pe/web/validador.xhtml during the two (02) years following the date of registration of the issuance program, period which has the character of non-extendable and must be directed exclusively to institutional investors, in accordance with what is established by the cited regulation.
Article 3°.- The placement of the securities to be registered
within the framework of the "First Program of Subordinated Bonds of Vívela" may be carried out provided that the term of the program has not expired.
Article 4°.- The securities issued within the framework of the
Regulation of the Market of Institutional Investors, solely, can be subject to offer, subscription, acquisition or placement among institutional investors, in accordance with what is established by article 6, numeral 6.10, of the cited regulation.
Article 5°.- In accordance with what is established by
article 6, numeral 6.8, of the Regulation of the Market of Institutional Investors and,
as long as Empresa de Crédito Vívela S.A. does not maintain securities registered in the Public Registry of the Securities Market under the general regime or the Alternative Market of Securities, the special regime of periodic and eventual information disclosure provided for in the cited regulation will apply to it.
Article 6°.- The competence of the Securities Market
Superintendence – SMV in the registration procedure referred to in article 1° of this resolution is limited solely to the verification of the presentation of the documentation or requirements established in the Regulation of the Market of Institutional Investors, without said verification implying a pronouncement or validation regarding its content, or a certification on the quality, the solvency of the issuer, nor on the risks of the security nor of the offer. Likewise, it does not correspond to the Securities Market Superintendence – SMV to pronounce on claims or complaints that might arise regarding said registration or regarding the offer of securities derived from it, without prejudice to the civil and/or penal responsibilities that might correspond to the responsible parties for the elaboration and presentation of the information.
Article 7°.- The registration of the issuance program to
which this resolution refers has not involved administrative activities of verification, nor inspection, nor audit of the information presented, nor an examination of the economic – financial situation of the issuer and does not imply certification by the Securities Market Superintendence – SMV on its quality, the solvency of the issuer, nor on the risks of the security or of the offer, in accordance with what is established by articles 21 and 24 of the Single Text of the Law of the Securities Market. Likewise, the registration of the issuance program and the registration of the respective informative prospectus does not imply that the Securities Market Superintendence – SMV recommends investment in the securities or gives an opinion favorable on the business prospects.
Article 8°.- To disseminate this resolution on the SMV Institutional
Website on the Digital Platform Unique of the Peruvian State for Citizen Orientation (www.gob.pe/smv).
Article 9°.- To transcribe this resolution to
Empresa de Crédito Vívela S.A., in the capacity of issuer; Acres Sociedad Broker Agent S.A., in the capacity of Representative of the Bondholders; to the Lima Stock Exchange S.A.; and, to CAVALI S.A. I.C.L.V. Register, communicate and disseminate. Sincerely, Alix Godos General Superintendent General Superintendent of Conduct Supervision