Lima, 20 August 2021

SUPERINTENDENCY OF BANKING, INSURANCE AND AFP Republic of Peru

Resolution S.B.S. No. 02451-2021

The Superintendent of Banking, Insurance and
Private Pension Fund Administrators

CONSIDERING:

That, by means of Resolution SBS No. 272-2017 and its amending provisions, the Corporate Governance and Integrated Risk Management Regulation was approved;

That, the aforementioned Regulation establishes that Integrated Risk Management is a process carried out by the board of directors, management and staff applied to the entire company and in the definition of its strategy, designed to identify potential events that may affect it, manage them in accordance with its risk appetite and provide reasonable assurance in the achievement of its objectives;

That, with the purpose of promoting adequate management of the disputes faced by supervised entities, it is necessary to establish the minimum procedures for their management, classification, reporting and provisioning, which have been formulated taking into consideration the experience acquired in the supervision actions carried out in recent years;

That, it is necessary to amend the Accounting Manual for Financial System Entities, approved by Resolution SBS No. 895-98 and its amending provisions, the Chart of Accounts for Insurance System Entities, approved by Resolution SBS No. 348-95 and its amending provisions, as well as the Accounting Manual for Private Pension Fund Administrators, approved by Resolution SBS No. 435-2005 and its amending provisions, in order to establish the accounting treatment of disputes and adapt it to the provisions related to the minimum procedures for the management, classification, reporting and provisioning for disputes;

That, likewise, it is necessary to amend the Internal Audit Regulation, approved by Resolution SBS No. 11699-2008 and its amending provisions, in order to consider provisions related to the management, classification, reporting and provisioning for disputes;

That, in order to gather the public's opinions on the proposal, the pre-publication of the draft regulation on the matter was arranged on the portal

of the Superintendence, pursuant to the provisions of Supreme Decree No. 001-2009- JUS;

With the endorsement of the Deputy Superintendencies of Banking and Microfinance, of Private Pension Fund Administrators, of Insurance, of Risks, of Legal Advice and of Economic Studies; and,

In exercise of the powers conferred by items 7 and 13 of Article 349 of the General Law of the Financial System and the Insurance System and Organic Law of the Superintendency of Banking and Insurance, Law No. 26702 and its amending provisions, and subsection d) of Article 57 of the Law of the Private Pension Fund Management System, whose Single Ordered Text is approved by Supreme Decree No. 054-97-EF;

RESOLVES:

Article First.- To approve the Minimum Procedures for the management, classification, reporting and provisioning for disputes, which form part of this Resolution:

“MINIMUM PROCEDURES FOR THE MANAGEMENT, CLASSIFICATION, REPORTING AND PROVISIONING FOR DISPUTES”

Article 1.- Scope

This regulation applies to the entities referred to in Articles 16 and 17 of the General Law of the Financial System and the Insurance System and Organic Law of the Superintendency of Banking and Insurance, Law No. 26702 and its amending provisions, to Private Pension Fund Administrators; as well as to the Banco de la Nación, the Banco Agropecuario, the Corporación Financiera de Desarrollo (COFIDE), the Fondo MIVIVIENDA S.A., the Derramas and Benefit Funds under the control of the Superintendency, and the Fund of Municipal Savings and Credit Banks (FOCMAC).

Article 2.- Definitions

For the application of this regulation, the following definitions must be considered:

a) Dispute.- Any conflict or disagreement that the company faces, among others, with clients, suppliers, workers, members of the Board of Directors, authorities or any third party, when the process or procedure has been initiated in a judicial, administrative, arbitral venue, or under any other legally recognized alternative dispute resolution mechanism, once the lawsuit or complaint has been notified, respectively, whose result may generate an outflow of resources from the company, under any concept. Disputes faced by Insurance Companies related to claims are not included, in those aspects that must be handled in accordance with the Claims Technical Reserve Regulation, approved by Resolution SBS No. 1856-2020.

b) Board of Directors.- Any reference to the board of directors also alludes to any equivalent governing body.

c) Accounting provisions.- Any reference to accounting provisions shall be understood as referring to the Accounting Manual for Financial System Entities, Chart of Accounts for Insurance System Entities, Accounting Manual for Private Pension Fund Administrators, or General Corporate Accounting Plan, as applicable.

d) Companies.- The entities referred to in Article 1 of this regulation. e) Dispute Manager.- Responsible for the submission of dispute reports. The Dispute Manager may also be responsible for the management and classification of the disputes if the company so defines. A primary manager must be designated, and it is at the discretion of the company to designate up to two alternate managers. The company must inform the Superintendency of the contact details of the organization's dispute manager. f) General Corporate Accounting Plan.- Approved by Resolution No. 002-2019-EF/30 and its amending provisions. g) Provision.- For the purposes of this regulation, it is a liability that is constituted by the controversies, in accordance with the accounting provisions. h) Superintendency.- Superintendency of Banking, Insurance and Private Pension Fund Administrators of Pensions.

Article 3.- Dispute Management

Companies must have a policies and procedures manual for dispute management, approved by the Board or a body with powers delegated by it, which shall include, at a minimum, the following aspects:

a) The list of areas and other participants in the dispute management process, together with the dispute manager, where applicable. Said process comprises from the receipt of complaints, lawsuits or notices of initiation of administrative actions, to the completion and definitive filing of disputes.

b) The procedure for handling ongoing disputes, considering the maximum action periods of each identified participant in accordance with item a).

c) The obligation to report to the Risk Committee, through periodic reports on operational risk management, the status of disputes in accordance with the information detail set forth in Article 5.

d) The procedure for monitoring the management of external legal counsel to whom disputes have been assigned. It must specify, at a minimum, the frequency with which such counsel will submit their written progress reports to the companies, as well as the mechanisms through which said companies will verify and evaluate the performance of the aforementioned external counsel.

e) The procedure for filing and retaining the principal records corresponding to each dispute.

f) The obligation to maintain an updated register of all their disputes, considering, at least, the following information: description of the case, amount claimed, judgment amount, accumulated provision amount as of the close of each reporting month, and their classification, in accordance with the categories indicated in item c) of Article 4.

Article 4.- Classification and Establishment of Provisions for Disputes

Companies must have a policies and procedures manual, approved by the Board or a body with powers delegated by it, which develops provisions regarding the classification of disputes; as well as for the establishment of provisions for disputes and disclosures in the financial statements, in accordance with the accounting provisions. Said regulations shall contain, at a minimum, the following aspects:

a) The areas and other participants in the classification and establishment of provisions for disputes process, together with the dispute manager, where applicable. The areas participating in the classification of disputes shall be distinct from the area in charge of the accounting records of disputes.

b) The procedure for the classification of disputes and the corresponding establishment of provisions, considering, at a minimum, the classification of disputes in accordance with item c); the reporting of information to the internal responsible for the accounting record of the constitution of provisions; the determination of provisions; the reporting of information to the Superintendency, in accordance with the detail of information set forth in Article 5; as well as, the recording of the cases that correspond in the database of operational risk loss events, in accordance with Circular SBS No. G-191-2017.

c) That the classification of disputes will be made based on the probability that an outflow of resources from the company will be generated, in accordance with the following categories:

i. Probable: this classification will be assigned upon the existence of facts, elements or a pronouncement of the authority that will resolve the dispute, that allow estimating that an outflow of resources from the company will be generated.

ii. Remote: this classification will be assigned upon the existence of facts, elements, or a pronouncement of the authority that will resolve the dispute, that allow estimating that an outflow of resources from the company will not be generated.

iii. Possible: this classification will be assigned when it is not possible to classify the outflow of resources from the company as Probable or Remote due to a dispute.

d) The classification must be made at the beginning of each dispute, and must be updated, at least, each time a relevant variation occurs in its status (judgment, resolution, arbitration award, ruling, new evidence or other relevant aspects, as applicable).

e) Every dispute that has a judgment, resolution, arbitration award or adverse ruling, as applicable, from any stage or instance, must be classified as 'probable'. Any exception to the indicated rule must be supported by binding jurisprudence and/or expert opinions; as well as have the prior approval of the Risk Committee. The supports of the exception must be available to the Superintendency.

f) Disputes may be classified as 'probable' even when they do not have a judgment, resolution, arbitration award or adverse ruling, as applicable, from any stage or instance, if from the analysis carried out by the area in charge of management and/or by the dispute manager, if applicable, it is concluded that there is a probability of outflow of resources for the company.

g) The constitution of provisions must consider, in addition to the principal obligation, other concepts that could derive from the same dispute; such as interest, costs and expenses, corrective measures ordered by the authority that resolves the dispute in order to repair any affectation caused, among others.

h) Companies must make the disclosures in the financial statements, in accordance with the provisions set forth in the accounting provisions.

Article 5.- Information on Disputes

5.1. Dispute Reports must be prepared, according to Annexes 1 and 2, which contain the following information

a) Annex 1:

• Section A - General report of disputes: Information regarding the total number of disputes against the company, as of the reporting date.

• Section B - Individual report of adverse and probable disputes: Information on disputes that have an adverse judgment, resolution, award or ruling, as applicable, at any stage or instance, for amounts exceeding 0.1% of the company's share capital (as of 31 December of the previous year) or exceeding two hundred fifty thousand soles (S/ 250,000.00), considering the lower amount between both. Likewise, disputes that, without an adverse pronouncement, are classified as probable must also be reported.

b) Annex 2:

• Individual report of disputes with adverse rulings not classified as probable:
  Information on all disputes that have a judgment, resolution, award or ruling adverse, as applicable, that as of the reporting date exceed the threshold established in
  Section B of Annex 1 mentioned in the preceding letter, but that have not been classified
  as probable, in accordance with the exception indicated in subsection e) of Article 4.

5.2. The Dispute Report indicated in Annex 1 must be signed and submitted to the Superintendency by the dispute manager, on a semi-annual basis. The form of submission will be defined by Multiple Official Letter.

5.3. The information indicated in Annex 2 must be updated semi-annually and be available to the Superintendency.

5.4. The dispute report formats indicated in Annexes 1 and 2 form part of this Resolution, which are published on the Institutional Portal –www.sbs.gob.pe – in accordance with the provisions of Supreme Decree No. 001-2009-JUS.

Article 6.- Prudential measures

The Superintendency may request additional information on certain disputes; as well as require rectifications in the classification of disputes, constitution of provisions, or other prudential measures, when, in its judgment, the classification of disputes, the provisions constituted or the application of exceptions present inconsistencies, are not duly supported and/or are insufficient.

Article Second.- Amend the Accounting Manual for Companies of the Financial System, in accordance with the following:

1. Incorporate in Section E "General Accounting Standards" of Chapter I "General Provisions", numeral 9 entitled "Accounting treatment of disputes" in accordance with the following text:

"9. Accounting treatment of disputes" For disputes that, in accordance with the Minimum Procedures for the management, classification, reporting and constitution of provisions for disputes, are classified as "probable", a provision must be recognized, forming part of the liability, with a corresponding expense, affecting the result of the period. Additionally, for the provisions, disclosures must be made in notes to the annual and quarterly financial statements, in accordance with the requirements of IAS 37 "Provisions, Contingent Liabilities and Contingent Assets" and the IFRS referring to interim and annual financial information.

The amount recognized as a provision must be the best estimate of the disbursement necessary to settle the liability, at the end of the annual or interim period being reported on.

In the case of disputes that are classified as "possible" in accordance with the Minimum Procedures for the management, classification, reporting and constitution of

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provisions for disputes, they must be disclosed in notes to the annual and quarterly financial statements, in accordance with the disclosure requirements for contingent liabilities of IAS 37 and the IFRS on presentation of interim and annual financial statements.

Regarding disputes classified as "remote" in accordance with the Minimum Procedures for the management, classification, reporting and constitution of provisions for disputes, they must not be recognized or disclosed in the quarterly and annual financial statements."

2. Replace in numeral 3 "Accounting Policies and Valuation Criteria" of letter B "Notes to the Financial Statements" of section I "Financial Statements" of Chapter II "Financial Statements and Complementary Information", the information referring to provisions, contingent liabilities and contingent assets, in accordance with the following text:

"o) Provisions, contingent liabilities and contingent assets Indicate the policy applied for the recognition of provisions, contingent liabilities and assets, in accordance with IAS 37 "Provisions, Contingent Liabilities and Contingent Assets". In the case of disputes in accordance with the provisions established in the Minimum Procedures for the management, classification, reporting and constitution of provisions for disputes, the guidelines established in Chapter I of this Manual must be followed."

3. Amend Chapter III "Chart of Accounts" and Chapter IV "Description and Dynamics of Accounts" in accordance with the following:

a) Replace the second paragraph of the description of item 27 "Provisions" in accordance with the following text:

"It also includes the provisions referred to in IAS 37 "Provisions, Contingent Liabilities and Contingent Assets". In the case of disputes in accordance with the provisions established in the Minimum Procedures for the management, classification, reporting and constitution of provisions for disputes, the guidelines established in Chapter I of this Manual must be followed."

b) Replace the second paragraph of the description of account 2702 "Other Provisions" in accordance with the following text:

"Provisions are also recorded within the framework of IAS 37 "Provisions, Contingent Liabilities and Contingent Assets". In the case of controversies in accordance with the provisions of the Minimum Procedures for the management, classification, reporting and constitution of provisions for controversies, the guidelines established in Chapter I of this Manual must be followed."

c) Replace the name of subaccount 2702.02 "Provisions for litigation and claims" with "Provisions for controversies".

d) Incorporate the description of subaccount 2702.02 called "Provisions for controversies" in accordance with the following text:

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"In this subaccount, provisions for controversies are recorded in accordance with the provisions of the Minimum Procedures for the management, classification, reporting and constitution of provisions for controversies, for which the guidelines established in Chapter I of this Manual must be followed."

e) Replace the second paragraph of the description of account 4305 "Provisions for contingencies and others" in accordance with the following text:

"It also includes expenses for provisions under IAS 37 "Provisions, Contingent Liabilities and Contingent Assets". In the case of controversies in accordance with the provisions of the Minimum Procedures for the management, classification, reporting and constitution of provisions for controversies, the guidelines established in Chapter I of this Manual must be followed."

f) Replace in the dynamics applicable to accounts 2701 and 2702, the credit "For the constitution of provisions for litigation and claims in accordance with IAS 37" with "For the constitution of provisions for controversies".

g) Replace the name of subaccount 4305.04 "Provisions for litigation and claims" with "Provisions for controversies".

h) Incorporate the description of subaccount 4305.04 called "Provisions for controversies" in accordance with the following text:

"In this subaccount, the expenses corresponding to provisions for controversies are recorded in accordance with the provisions of the Minimum Procedures for the management, classification, reporting and constitution of provisions for controversies, for which the guidelines established in Chapter I of this Manual must be followed."

i) Replace in the dynamics applicable to accounts 4301, 4302, 4303, 4304 and 4305, the debit "For the charge of the provision for contingencies" with "For the charge of the provision for controversies".

Article Three.- Modify the Chart of Accounts for Insurance System Companies, in accordance with the following:

1. Incorporate in the Conceptual Accounting Framework, in the section "SPECIFIC ACCOUNTING PROVISIONS", the following Section:

"ACCOUNTING TREATMENT OF CONTROVERSIES

For controversies that, in accordance with the Minimum Procedures for the management, classification, reporting and constitution of provisions for controversies, are classified as "probable", a provision must be recognized, forming part of the liability, with a corresponding expense, affecting the result of the year. Additionally, for the provisions, disclosures must be made in notes to the annual and interim financial statements, in accordance with the disclosure requirements of IAS 37 "Provisions,

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Contingent Liabilities and Contingent Assets" and the IFRS on presentation of interim and annual financial statements.

The amount recognized as a provision must be the best estimate of the disbursement necessary to settle the liability, at the end of the annual or interim period being reported on.

In the case of controversies that are classified as "possible" in accordance with the Minimum Procedures for the management, classification, reporting and constitution of provisions for controversies, they must be disclosed in notes to the annual and interim financial statements, in accordance with the disclosure requirements for contingent liabilities of IAS 37 and the IFRS on presentation of interim and annual financial statements."

Regarding controversies classified as "remote" in accordance with the Minimum Procedures for the management, classification, reporting and constitution of provisions for controversies, they must not be recognized or disclosed in the interim and annual financial statements".

2. Replace in numeral 3 "Accounting Policies and Valuation Criteria" of literal A "Annual Financial Statements" of the Section "Minimum Notes to the Financial Statements" of Chapter I "General Provisions", the information referring to provisions, contingent liabilities and contingent assets, in accordance with the following text:

"q) Provisions, contingent liabilities and contingent assets Indicate the policy applied for the recognition of provisions, contingent liabilities and assets, in accordance with IAS 37 "Provisions, Contingent Liabilities and Contingent Assets". In the case of controversies in accordance with the provisions of the Minimum Procedures for the management, classification, reporting and constitution of provisions for controversies, the guidelines established in the Conceptual Accounting Framework of this Plan must be followed.

3. Modify Chapter III "Accounting Table and Chart of Accounts", as well as Chapter IV "Description and Dynamics" in accordance with the following:

a) Replace the name of account 2803 "Litigation with third parties" with "Provisions for controversies".

b) Incorporate the description of account 2803 "Provisions for controversies" in accordance with the following text:

"In this subaccount, provisions for controversies are recorded in accordance with the provisions of the Minimum Procedures for the management, classification, reporting and constitution of provisions for controversies, for which the guidelines established in the Conceptual Accounting Framework of this Plan must be followed."

c) Replace in the dynamics of item 28 "Other Liabilities", the credit with the following:

“For the constitution of the liabilities corresponding to the fiscal year for compensation for time of service, vacations, bonuses, retirement, provisions for disputes and others”.

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d) Replace the description of account 4709 “Miscellaneous expenses” according to the following text:

“It comprises the losses incurred in the sale of fixed assets and expenses different from the company's operations. Likewise, this account records the expenses corresponding to provisions under IAS 37 “Provisions, Contingent Liabilities and Contingent Assets”. In the case of disputes, in accordance with the Minimum Procedures for the management, classification, reporting and constitution of provisions for disputes, the guidelines established in the Conceptual Accounting Framework of this Plan must be followed.”

e) Incorporate into account 4709 the subaccount 4709.04 called “Provisions for disputes” and incorporate the following description:

“This subaccount records the expenses corresponding to provisions for disputes in accordance with the Minimum Procedures for the management, classification, reporting and constitution of provisions for disputes, for which the guidelines established in the Conceptual Accounting Framework of this Plan must be followed.”

f) Replace in the dynamics of account 4709 “Miscellaneous Expenses”, the debit “For the resolution of contingencies” with “For the provision for disputes”.

Article Four.- Amend the Accounting Manual for Private Pension Fund Administrators, according to the following:

1. Incorporate into the Conceptual Accounting Framework the following Section:

“ACCOUNTING TREATMENT OF DISPUTES

For disputes that, in accordance with the Minimum Procedures for the management, classification, reporting and constitution of provisions for disputes, are classified as “probable”, a provision must be recognized, forming part of the liability, with an expense as a counterpart, affecting the result for the year. Additionally, for provisions, disclosures must be made in notes to the annual and interim financial statements, in accordance with the disclosure requirements of IAS 37 “Provisions, Contingent Liabilities and Contingent Assets” and the IFRS on presentation of interim and annual financial statements.

The amount recognized as a provision must be the best estimate of the disbursement necessary to settle the liability, at the end of the annual or interim period being reported on.

In the case of disputes classified as “possible” in accordance with the Minimum Procedures for the management, classification, reporting and constitution of provisions for disputes, they must be disclosed in notes to the annual and interim financial statements, in accordance with the requirements of IAS 37 and the IFRS on presentation of interim and annual financial statements.

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Regarding disputes classified as “remote” in accordance with the Minimum Procedures for the management, classification, reporting and constitution of provisions for disputes, they must not be recognized or disclosed in the interim and annual financial statements”.

2. Replace in item 3 “Accounting Policies and Valuation Criteria” of subsection A “Annual Financial Statements” of Chapter II “Financial Statements, Presentation Deadlines”, the information regarding provisions, contingent liabilities and contingent assets, according to the following text:

“l) Provisions, contingent liabilities and contingent assets Indicate the policy applied for the recognition of provisions, contingent liabilities and assets, in accordance with IAS 37 “Provisions, Contingent Liabilities and Contingent Assets”. In the case of disputes, in accordance with the provisions of the Minimum Procedures for the management, classification, reporting and constitution of provisions for disputes, the guidelines established in the Conceptual Accounting Framework of this Manual must be followed.”

3. Amend in Chapter IV “Description and Dynamics of Accounts” the following:

a) Replace the description of class 2 “Liability” according to the following text:

“It groups the accounts that represent obligations contracted with the company for business operations, as well as provisions.

It comprises the items: taxes payable and contributions, remuneration and participations payable, suppliers, obligations of the Longevity Fund, obligations of the Complementary Fund, dividends payable, miscellaneous accounts payable, employee social benefits, provision for negligence, other provisions, as well as income tax.”

b) Replace the description of item 2048 “Provision for negligence and other provisions” according to the following text:

“The provision for negligence comprises the obligations contracted by the AFP with respect to the Pension Funds it administers, for those pension contributions owed to employees and for which, negligently, it did not carry out the corresponding collection actions.

The recognition, measurement and disclosure of other provisions, different from provisions for negligence, shall be carried out in accordance with IAS 37 “Provisions, Contingent Liabilities and Contingent Assets”, except for disputes within the framework of the provisions of the Minimum Procedures for the management, classification, reporting and constitution of provisions for disputes, which must follow the guidelines established in the Conceptual Accounting Framework of this Manual.”

Article Five.- The companies included in the scope of the Minimum Procedures for the management, classification, reporting and constitution of provisions for disputes, approved by Article One of this Resolution, that apply the Plan

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General Business Accounting approved by Resolution Nº 002-2019-EF/30 and its amending norms, must follow the accounting treatment indicated below:

Accounting treatment of disputes:

1. For disputes that, according to the Minimum Procedures for the management, classification, reporting and constitution of provisions for disputes, are classified as "probable", a provision must be recognized, forming part of the liability, with a corresponding expense, affecting the result of the fiscal year. Additionally, the provision must be disclosed in notes to the annual and interim financial statements, in accordance with the requirements of IAS 37 "Provisions, Contingent Liabilities and Contingent Assets" and the IFRS on presentation of interim and annual financial statements.

The amount recognized as a provision must be the best estimate of the disbursement necessary to settle the liability, at the end of the annual or interim period being reported on.

2. Disputes that are classified as "possible" according to the Minimum Procedures for the management, classification, reporting and constitution of provisions for disputes, must be disclosed in notes to the annual and interim financial statements, in accordance with the requirements of IAS 37 and the IFRS on presentation of interim and annual financial statements.

Article Six.- Amend the Internal Audit Regulation, approved by SBS Resolution N° 11699-2008 and its amending norms, in accordance with the following:

1. Incorporate in section I "Companies indicated in literals A, B and C of article 16° of the General Law (except bonding and guarantee companies), Banco de la Nación, Banco Agropecuario, Fondo MIVIVIENDA and Corporación Financiera de Desarrollo (COFIDE)" of Annex "Programmed Activities", the following:

"20) Evaluation of compliance with the provisions indicated in the Minimum Procedures for the management, classification, reporting and constitution of provisions for disputes."

2. Incorporate in Section II "Insurance and/or reinsurance companies" of Annex "Programmed Activities", the following:

"21) Evaluation of compliance with the provisions indicated in the Minimum Procedures for the management, classification, reporting and constitution of provisions for disputes."

3. Incorporate in Section III "Complementary and related services companies" of Annex "Programmed Activities", the following:

"10) Evaluation of compliance with the provisions indicated in the Minimum Procedures for the management, classification, reporting and constitution of provisions for disputes."

4. Incorporate in Section IV "Bonding and guarantee companies" of Annex "Programmed Activities", the following:

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"12) Evaluation of compliance with the provisions indicated in the Minimum Procedures for the management, classification, reporting and constitution of provisions for disputes."

5. Incorporate in Section V "Distributions and pension funds" of Annex "Programmed Activities", the following:

"10) Evaluation of compliance with the provisions indicated in the Minimum Procedures for the management, classification, reporting and constitution of provisions for disputes."

6. Incorporate in Section VI "Private Pension Fund Administrators (AFP)", the following:

"11) Evaluation of compliance with the provisions indicated in the Minimum Procedures for the management, classification, reporting and constitution of provisions for disputes."

Article Seven.- Companies must submit to this Superintendency an adaptation plan to the provisions of this Resolution, within a period that must not exceed sixty (60) days from the date of its publication, which must contain the adaptation schedule and the actions planned for it, as well as the name and position of the officials responsible for compliance with said plan.

Article Eight.- Effective Date

1. Article One of this Resolution enters into force on 01 January 2022.

2. Articles Two, Three, Four and Five of this Resolution enter into force as of the information corresponding to January 2022.

3. Article Six of this Resolution enters into force as of the audit corresponding to fiscal year 2022.

4. Article Seven of this Resolution enters into force on the day following its publication.

5. The first dispute report, established in Article 5 of the Minimum Procedures for the Management, Classification, Reporting and Constitution of Provisions for Disputes, approved by Article One of this Resolution, shall be submitted with information corresponding to the month of June 2022

Register, communicate and publish,

MARÍA DEL SOCORRO HEYSEN ZEGARRA
Superintendent of Banking, Insurance and Private Administrators of Pension Funds

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ANNEX N° 1 Section "A": General Report of Disputes

Name of the Supervised Company
			Information updated as of: dd/mm/yyyy
Subject Matter of Dispute	# Cases (1)	# Cases S/R/L (2)	Accum. Amount Judgment (3)	Accum. Amount Provisions (4)
Civil / Commercial
Labor (Incl. P. Amparo)
Criminal
Contentious Administrative
Arbitration
Adm. INDECOPI
Adm. SBS/SMV/BCR
Adm. SUNAT
Other Administrative
Others (Specify)
Total

Instructions:

In this table, information regarding disputes against the company must be recorded.

(1) The number of cases, by subject matter, that are ongoing must be indicated, considering for this purpose all those that have been admitted for processing and have not yet been definitively archived.

(2) The number of cases with a judgment, resolution, arbitration award or other ruling, by subject matter, that would generate an outflow of resources from the company must be indicated (even those that only involve the payment of costs and expenses shall be considered as adverse rulings).

(3) The accumulated amount of the judgments, resolutions, arbitration awards and other (valid) rulings, by subject matter, that would generate an outflow of resources from the company must be indicated. For the calculation of the amounts to be recorded, interest, costs, expenses, or any

other concept to be paid must be considered, even if they have not yet been defined by the corresponding authority, for which the best estimate of the possible outflow must be made in accordance with expert criteria.

(4) The accumulated amount of the provisions, by subject matter, that have been recorded in the corresponding account in accordance with accounting provisions must be indicated.

ANNEX No. 1 Section "B": Individual Disputes Report

Name of the Supervised Company								Information updated as of: dd/mm/yyyy
No.	Name of the Plaintiff(s)	File No.	Subject matter(1)	Summary of the Case(2)	Amount of the Claim(3)	Current Instance(4)	Amount of the Ruling (5)	Provisioned Amount (6)

Instructions:

In this table, disputes must be recorded whose rulings involve an outflow of resources that is equal to or greater than 0.1% of the share capital (as of 31 December of the previous year) or that exceed two hundred fifty thousand soles (S/ 250,000.00); considering the lower amount between both.

Likewise, disputes that, without an adverse pronouncement, are classified as probable must be reported (regardless of the amount involved)

(1) The subject matter to which the dispute corresponds must be indicated, in accordance with the detail included in section A of Annex No. 1.

(2) Summarize the causes that gave rise to the process (if applicable, specify the product or business line impacted).

(3) Indicate the amount claimed by the counterparty, only in cases where it has been quantified.

(4) Indicate the instance in which the process is found (first, second or other if applicable).

(5) Indicate the amount of the latest judgment or resolution or adverse ruling, as applicable. If partial payments have been made, they shall be deducted.

(6) Indicate the amount of the provision constituted for the dispute.

SUPERINTENDENCY OF BANKING, INSURANCE AND AFP Republic of Peru

Los Laureles No. 214

• Lima 27
• Peru Tel.: Tel.: (511) 6309000 Fax: (511) 6309239

Los Laureles No. 214 - Lima 27 - Peru Tel.: Tel.: (511) 6309000 Fax: (511) 6309239

ANNEX No. 2 Individual report of disputes with adverse rulings not classified as probable

Name of the Supervised Company								Information updated as of: dd/mm/yyyy
No.	Plaintiff(s)/ Complainant(s)	File No.	Subject matter(1)	Summary of the Case(2)	Amount of the Claim(3)	Current Instance(4)	Amount of the Ruling(5)	Basis for Exception (6)	Detail of the Basis for Exception(7)

Instructions:

In this table, all disputes with adverse rulings must be recorded that, as of the reporting date, exceed the threshold established in article 5 of the Minimum Procedures for the management, classification, reporting and constitution of provisions for disputes, but that have not been classified as probable, in accordance with the exception indicated in subsection e) of article 4 of the aforementioned regulation. The amounts must be expressed in soles.

(1) The subject matter to which the dispute corresponds must be indicated, in accordance with the detail included in Section A of Annex No. 1.

(2) Summarize the causes that gave rise to the process. If applicable, specify the product or business line involved in each case.

(3) Indicate the amount claimed by the counterparty, only in cases where it has been quantified.

(4) Indicate the instance in which the case is currently found (first, second or other if applicable).

(5) Indicate the amount of the latest judgment or resolution or adverse ruling, as applicable (if partial payments have been made, they shall be subtracted from the amount of the adverse ruling). In cases of disputes of an administrative contentious nature, the amount of the latest ruling of the administrative instance must be indicated, if a new ruling has not yet been issued in the judicial instance.

(6) Indicate whether the exception is based on: Binding jurisprudence or Expert opinions.

(7) The arguments supporting the application of the exception must be summarized.