Resolution of the Assistant Superintendent of Prudential Supervision No. 008-2026-SMV/10 — SMV — PE

PERU Ministry of Economy and Finance

SMV
Superintendence of the Securities Market
"Decade of Equal Opportunities for Women and Men"

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Resolution of the Assistant Superintendent of Prudential Supervision No. 008-2026-SMV/10 Lima, January 22, 2026

Subject: The administrative sanctioning procedure initiated against ANKA Sociedad Administradora de Fondos de Inversión S.A. is declared archived, and consequently, said administrative procedure is concluded.

Administered Entity: ANKA Sociedad Administradora de Fondos de Inversión S.A.
Subject: Administrative sanctioning procedure
File No.: 2025054683

The Assistant Superintendent of Prudential Supervision

HAVING SEEN:

Administrative file No. 2025054683, and Report No. 039-2026-SMV/10.3, issued by the General Superintendence of Prudential Compliance; as well as the defenses presented by ANKA Sociedad Administradora de Fondos de Inversión S.A.; and,

CONSIDERING:

Pursuant to Article 1 of Law No. 29782, Law for the Strengthening of the Supervision of the Securities Market, the name of the National Commission for the Supervision of Companies and Securities (CONASEV) is replaced by that of the Superintendence of the Securities Market (SMV); therefore, any reference to CONASEV in legal norms shall be understood as a reference to the SMV;

I. FACTS

Within the supervisory functions assigned to the SMV, an evaluation of compliance in the presentation of periodic information by ANKA Sociedad Administradora de Fondos de Inversión S.A. (hereinafter, ANKA SAFI) was carried out;
As a result of said evaluation and under the authority of the Single Text of the General Administrative Procedure Law No. 27444, approved by Supreme Decree No. 004-2019-JUS (hereinafter, TUO LPAG), through Letter No. 7323-2025-SMV/10.3, notified on December 18, 2025 (hereinafter, CHARGES LETTER), an administrative sanctioning procedure was initiated against ANKA SAFI for violations of the Regulation of Investment Funds and its Managing Societies approved by SMV Resolution No. 029-2014-SMV-01 (hereinafter, FI REGULATION) and the "Norms on the preparation and presentation of Financial Statements and Annual Report by entities supervised by the

PERU Ministry of Economy and Finance

SMV
Superintendence of the Securities Market
"Decade of Equal Opportunities for Women and Men"

Superintendence of the Securities Market", approved by SMV Resolution No. 016-2015-SMV/01 and its amendments" (hereinafter, NORMS), for not presenting its individual interim financial statements and its respective management report corresponding to the fourth quarter of the 2021 fiscal year, with the deadline for their approval and presentation being February 15, 2022;

The aforementioned non-compliance is classified as a serious offense, according to what is established in Annex I, item 2, subsection 2.10 of the Sanctions Regulation, approved by SMV Resolution No. 035-2018-SMV/01 (hereinafter, SANCTIONS REGULATION), according to which it constitutes an offense: "To not communicate important facts or not present audited individual or consolidated financial statements, individual or consolidated interim financial statements, management report or special audit report and annual reports";
Through a document presented on December 30, 2025, ANKA SAFI presented the defenses requested by the CHARGES LETTER;
The charge formulated, as well as the defenses presented by ANKA SAFI, have been the subject of evaluation by the General Superintendence of Prudential Compliance in Report No. 039-2026-SMV/10.3, which has been submitted to the knowledge of this Assistant Superintendence;
In observance of the Principle of Due Process contemplated in Article IV, subsection 1, item 1.2 of the Preliminary Title, as well as in Article 248, item 2, of the TUO LPAG, through Letter No. 151-2026-SMV/10, the administrative file to which this resolution refers was made available to ANKA SAFI for its review;

II. MATTERS TO BE DETERMINED

In the present administrative procedure, in the opinion of this Assistant Superintendence, it corresponds to determine the following:

a. Whether ANKA SAFI incurred or did not incur an offense by not presenting ANKA SAFI's individual interim financial statements and its respective management report corresponding to the fourth quarter of the 2021 fiscal year, with the maximum deadline for their approval and presentation being February 15, 2022.

b. Whether it corresponds or does not correspond to impose a sanction on ANKA SAFI;

III. ANALYSIS

3.1 On the applicable regulations

Regarding the submission of financial information by investment fund managing societies, Article 133 of the FI REGULATION indicates the following:

"Article 133 Financial Information of the Managing Society The Managing Society must submit to the Registry the following information regarding itself:

a) The intermediate financial information, individual and consolidated, and the respective Management analysis and discussion, as applicable, in accordance with what is established in the applicable accounting standards.
(….)

PERU Ministry of Economy and Finance

SMV
Superintendence of the Securities Market
"Decade of Equal Opportunities for Women and Men"

The deadlines for the presentation of financial information shall be established by a general nature norm issued by the SMV. The annual report must be presented at the same time as the presentation of the audited annual financial information.";

Pursuant to the aforementioned, Articles 2 and 5 of the NORMS establish the following:

"Article 2.- Obligation to present financial information and annual report Issuing companies with securities registered in the RPMV, legal entities registered in the RPMV, collective fund management companies, and Investment Funds, are obliged to present to the SMV their annual individual or separate financial statements and interim individual or separate financial statements and annual report. Additionally, issuing companies with securities registered in the RPMV, legal entities registered in the RPMV whose special regulation requires it, and Investment Funds must prepare the Management Report referred to in Chapter VIII of the Financial Information Regulation, in accordance with the guidelines indicated in the Third Section of the Manual for the preparation of financial information, and present it together with the individual or separate interim financial statements."

"Article 5.- Deadlines for the presentation of individual or separate and consolidated interim financial statements Issuing companies with securities registered in the RPMV, legal entities registered in the RPMV, and collective fund management companies must present the individual or separate interim financial statements and consolidated interim financial statements, as applicable, to the SMV and, if applicable, to the entities responsible for the management of centralized negotiation mechanisms, on the day they were approved by the corresponding body. These entities have as the deadline for the respective approval of the individual or separate interim financial statements for the first three quarters April 30, July 31, and October 31 of each year; (…) For the fourth quarter, the deadline for the approval of the individual or separate interim financial statements is February 15 of each year (…)";

3.2 On the charges formulated

Through the CHARGES LETTER, a charge was formulated against ANKA SAFI for not presenting, within the deadline established by the regulations, the periodic information indicated in the third consideration of this resolution;

3.3 On the defenses presented

In its defenses, ANKA SAFI states that the financial information subject to the charge was presented on May 3, 2022, through file No. 2022019352, and therefore requests that it be declared that the offense imputed in the terms set forth in the CHARGES LETTER has not been configured;

3.4 Evaluation of the defenses

As indicated in the CHARGES LETTER, the deadline for the approval and presentation of ANKA SAFI's individual interim financial statements and its respective management report corresponding to the fourth quarter of the 2021 fiscal year was February 15, 2022;

PERU Ministry of Economy and Finance

SMV
Superintendence of the Securities Market
"Decade of Equal Opportunities for Women and Men"

However, from the evaluation carried out, it has been determined that ANKA SAFI presented its individual interim financial statements and its respective management report for the fourth quarter of 2021 on May 3, 2022, through file No. 2022019352, that is, with seventy-seven (77) days of delay;
In that sense, since the present administrative sanctioning procedure was initiated under the assumption of omission due to the non-presentation of the financial information and its respective management report observed, it does not correspond to continue the present procedure under the infringing type established in Annex I, item 2, subsection 2.10 of the SANCTIONS REGULATION;
Being in accordance with what is provided in Article 32, item 16, of the Regulation of Organization and Functions of the SMV, approved by Supreme Decree No. 216-2011-EF and its amendments;

RESOLVES:

Article 1.- To declare that it does not correspond to sanction ANKA Sociedad Administradora de Fondos de Inversión S.A. for the offense typified in Annex I, item 2, subsection 2.10 of the Sanctions Regulation, approved by Resolution No. 035-2018-SMV/01, in accordance with what is stated in the considering part of this resolution; and, consequently, proceed to archive the present administrative sanctioning procedure.

Article 2.- To transcribe this resolution to ANKA Sociedad Administradora de Fondos de Inversión S.A.

Omar Gutiérrez Ochoa
Assistant Superintendent
Assistant Superintendence of Prudential Supervision