Superintendence Resolution No. 033-2026-SMV/11

PERU Ministry of Economy and Finance

SMV
Securities Market
Superintendence
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 authorship Superintendence Resolution Adjunct SMV No. 033-2026-SMV/11 Lima, August 27, 2026 Subject: Sanction REFINERIA LA PAMPILLA S.A.A. with a fine of 2.86 UIT for having committed one (01) minor infraction type in paragraph 3.1 of section 3 of Annex I of the Sanctions Regulation Administered: REFINERIA LA PAMPILLA S.A.A. Subject: Administrative Sanctioning Procedure of single administrative instance Main Type: Paragraph 3.1 of section 3 of Annex I of the Sanctions Regulation MINOR INFRACTIONS File No.: 2026024046 The Adjunct Superintendent of Supervision of Market Conduct SEEN:
The administrative file No. 2026024046, containing the administrative sanctioning procedure initiated by the General Superintendent of Conduct Compliance of the Securities Market Superintendence – SMV (hereinafter, the IGCC), against Refinería La Pampilla S.A.A. (hereinafter, the Issuer); as well as Report No. 995-2026-SMV/11.2 (hereinafter, the Report), issued by the IGCC; CONSIDERING:
I. FUNCTION AND COMPETENCE OF THE SASCM

1. That, the IGCC – the instructing body of the
   administrative sanctioning procedures (hereinafter, the PAS) referred to in the case at hand – has brought to the attention of the Adjunct Superintendence of Supervision of Market Conduct of the SMV (hereinafter, SASCM), the PAS of the administrative file No. 2026024046, with the aim that it issues a decision as the sanctioning body of single administrative instance, as appropriate for the type of infractions evaluated in said PAS. In this way, the SASCM assumes competence in

PERU Ministry of Economy and Finance

SMV
Securities Market
Superintendence
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 authorship observance of the exercise of the supervisory function and of the sanctioning power of the Securities Market Superintendence – SMV established through the Unified Concordant Text of its Organic Law, Decree Law No. 26126 (hereinafter, LOSMV), and the Unified Text of the Securities Market Law, Legislative Decree No. 861, approved by Supreme Decree No. 020-2023-EF-11 (hereinafter, TUO 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 on Organization and Functions of the Securities Market Superintendence – SMV, approved by Supreme Decree No. 216-2011-EF (hereinafter, ROFSMV), in the sense that it is a specific function of the SASCM, to impose sanctions in single administrative instance. Likewise; the SASCM has the powers to dictate corrective measures aimed at reversing the situation altered by the commission of the infraction;
II. FACTS, CHARGES AND DEFENSES OF THE ISSUER
2.1. Facts
2. That, it was evaluated whether the Issuer complied or not with
presenting to the securities market its material facts in a complete and timely manner;
2.2. Charge
3. That, as a result of said evaluation,
through Office No. 2333-2026-SMV/11.2 (hereinafter, Office of Charges), charges were formulated against the Issuer for not having complied with presenting within the established deadline the material fact referred to the approval, through Board of Directors Session of October 22, 2025, of the hiring of the auditing company Ernst & Young Consultores S.C.R.L. to issue the report required by the penultimate paragraph of paragraph c) of
article 51 of the TUO LMV, for which it had to be communicated on the same day the selection of the external entity was approved; however, it was communicated on October 30, 2025. (File No. 2025047387);
2.3. Defenses
4. That, through a document presented on June 04,
2026, the Issuer presented its defenses pointing out; among others, the following:
(i) On voluntary remediation as an exemption from liability The Issuer requests, as a preliminary matter, that the nullity of the Office of Cargo be declared through which the initiation of the present procedure administrative sanctioning, alleging that prior to such action the causal exemption from liability for voluntary remediation provided for in paragraph f) of section 1 of article 257 of the Unified Text Ordered of Law No. 27444, General Administrative Procedure Law, approved by Supreme Decree No. 004-2019-JUS. Regarding this, it states that the imputed fact was voluntarily remediated through the presentation of the corresponding material fact on October 30, 2025, while the Office of Charges was notified only on May 21,
2026. Therefore, the Issuer maintains that the remediation occurred before
the notification of the charge imputation and that, consequently, the exemption from liability provided for in the cited normative text was configured.

PERU Ministry of Economy and Finance

SMV
Securities Market
Superintendence
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 authorship It adds that such action was carried out voluntarily, diligently and without prior request from the SMV, which would demonstrate its good faith and commitment to compliance with its regulatory obligations. By virtue of this, it considers that the sanctioning procedure should never have been initiated and that it corresponded to the final archiving of the file. Likewise, it argues that there is no legal provision that excludes or limits the application of the figure of voluntary remediation with respect to the infraction imputed, for which it requests that the declaration of nullity of the Office of Charges and the final archiving of the procedure be recommended. (ii) On the application of mitigating criteria for the infraction and criteria for infraction grading Subsidiarily, in the event that the requested nullity is not declared and the processing of the procedure continues, the Issuer states that it does not question the commission of the imputed fact, indicating that the voluntary remediation itself effected constitutes an implicit recognition of responsibility. In this sense, it expressly formulates the recognition of administrative responsibility with respect to the imputed fact, invoking the application of the mitigating circumstance provided for in paragraph a) of section 2 of article 236-A of the TUO of the LPAG and in article 26 of the Sanctions Regulation, referred to the express and written recognition of the infraction once the administrative sanctioning procedure has started. Likewise, it requests the application of the mitigating factor consisting in the contribution to the clarification of the infraction, stating that it regularized the presentation of the material fact without prior request from the SMV and collaborated with the determination of the facts subject of the procedure. Additionally, it requests that various circumstances be considered for the graduation of the eventual sanction, among them:

• The non-existence of economic harm or repercussion in the market, due to
  the fact that the shares issued by the company are not listed on any stock exchange;
• The non-existence of affectation to public interest or to the protected legal good, since
  the information was finally made known to the market and the transparency or integrity of the securities market would not have been affected;
• The non-existence of illicit benefit derived from the imputed conduct;
• The absence of intent in the non-compliance; and,
• The high probability of detection of the infraction by the SMV, given
  that this entity is the direct recipient of the Material Facts.
  Finally, the Issuer reiterates that the imposition of a sanction would not correspond due to the remediation effected. However, subsidiarily, it requests that the invoked mitigating circumstances and graduation criteria be valued, with the effect that the sanction of the least severity possible be imposed, by considering that any more serious consequence would be disproportionate in relation to the imputed fact.

5. That, the Unified Text Ordered of Law No. 27444,
   General Administrative Procedure Law, approved by Supreme Decree No. 006-

PERU Ministry of Economy and Finance

SMV
Securities Market
Superintendence
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 authorship 2026-JUS (hereinafter, TUO of the LPAG) 1 , contains common norms for the actions of the administrative function of the State and regulates all procedures administrative developed in the entities, including the procedures special. Likewise, section 3) of article 230 of the TUO of the LPAG, points out the criteria regarding the graduation of the sanction: (a) The illicit benefit resulting from the commission of the infraction, (b) The probability of detection of the infraction, (c) The gravity of the damage to public interest and/or protected legal good, (d) The economic harm caused, (e) Recidivism, for the commission of the same infraction within the term of one (1) year from when the resolution that sanctioned the first infraction became final, (f) The circumstances of the commission of the infraction and, (g) The existence or not of intent in the conduct of the offender;
6. That, the charges, the defenses 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;
7. That, in observance of what is provided for in section
5 of article 235 of the TUO of the LPAG, through Office No. 3188-2026-SMV/11 of July 08 2026, the Report was sent to the Issuer so that it could formulate its allegations within the term of five (05) business days, which as of today have not been presented;
III. QUESTIONS TO BE DETERMINED
8. That, in the present PAS it corresponds to determine
the following:
(i) Whether the Issuer incurred or not in the infractions indicated in the Office of Charges and Report; (ii) Whether it corresponds or not to impose a sanction on the Issuer;
IV. ANALYSIS
4.1. Applicable Normativity
9. That, article 30 of the TUO LMV establishes the following:
“Article 30.- Material Facts
The registration of a certain value 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 value and the offer that is made of it, as well as to disclose such facts in a truthful, sufficient and timely manner. The information must be provided to these institutions and disclosed as soon as the fact occurs or the issuer takes knowledge of it, as the case may be”. (Underline added);
10. That, now, paragraph c) of article 51 of the TUO
of the LMV states the following:

1 By Supreme Decree No. 006-2026-JUS, published on April 30, 2026 in the Official Journal El Peruano, the Unified Text Ordered of Law No. 27444 General Administrative Procedure Law was approved, approved by Supreme Decree No. 006-2026-JUS.

PERU Ministry of Economy and Finance

SMV
Securities Market
Superintendence
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 authorship “Article 51.- Obligation of the Issuer.- Issuers with values registered in the Registry are subject to the following norms:
(…) c) For the celebration of each act or contract involving at least five percent of the assets of the issuing society with natural or legal persons linked to their directors, managers or shareholders who directly or indirectly represent more than ten percent of the capital of the society, prior approval of the board of directors is required, without the participation of the director who has linkage. For the purposes of the determination of the five percent, the last financial statements corresponding must be taken into account. In transactions in which the controlling shareholder of the issuing society also exercises control of the legal person that participates as a counterparty in the respective act or contract subject to prior approval by the board of directors, it is additionally required the review of the terms of said transaction by an entity external to the issuing society. An external entity shall be considered to be such a society the auditing societies or other legal persons that by provisions of general character determine Conasev. (…) It corresponds to Conasev to define the scope of the terms control and linkage and regulate the participation of the external entity to the society and the other aspects of the present article. (…)”. (Underline added);
11. That, regarding this, article 12 of the Provisions
for the application of paragraph c) of article 51 of the Securities Market Law, approved by SMV Resolution No. 029-2018-SMV/01 (hereinafter, Provisions for the application of paragraph c) of article 51 of the LMV), specifies:
“Article 12.- MATERIAL FACTS
The approval by the Board of Directors or the General Shareholders' Meeting, as appropriate, of an Act or contract included in paragraph c) of article 51 of the Law, the selection of the external entity that will carry out the report referred to in the penultimate paragraph of said article, as well as the receipt of the report, must be communicated as material facts, (…).” (Underline added);
12. That, being so, its representative would have
failed to comply with the obligation to send said material fact in a timely manner, in accordance with what is required in section 9.1 of article 9 of the Regulation on Material Facts and Confidential Information, approved by SMV Resolution No. 005-2014- SMV/01 (hereinafter, Regulation on Material Facts): “The Issuer must inform its material fact as soon as such fact occurs or the Issuer takes knowledge of it, and in no case beyond the day on which it has occurred or has been known (…);
13. That, for the purposes of determining possible
sanctions, infractions for communicating material facts out of time must be noted that according to what is provided for in paragraph 3.1 of
section 3 of Annex I of the Sanctions Regulation, it states that it constitutes a minor infraction:

PERU Ministry of Economy and Finance

SMV
Securities Market
Superintendence
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 authorship “Presenting outside the established deadline, or doing so in an incomplete manner, or, without observing the technical specifications approved by the SMV or without communicating the approval by
part of the corresponding corporate body, to the SMV, to the Stock Exchange, to the entity in charge
of the centralized trading mechanism or to any other entity or subject of the securities market, the individual or consolidated audited financial information, the individual or consolidated interim financial statements, management report, special audit report, material facts and, annual reports.” (Underline added);
14. That, according to what is established in article
35 of the Sanctions Regulation, it corresponds that these infractions be sanctioned with a reprimand or fine not less than one (1) UIT and up to the limit of twenty-five (25) UIT;
4.2. Evaluation of the case
15. That, in the administrative file No.
2026024046, which contains the documentation of the present PAS, it is appreciated that through Memorandum No. 890-2026-SMV/11.1 of February 26, 2026 (File No. 2026009017), the General Superintendent of Conduct Supervision (hereinafter, IGSC) – the body of the Securities Market Superintendence – SMV that has within its functions and powers, the supervision of compliance with the norms applicable to issuer companies with values registered in the RPMV, evaluating the indications of possible infractions, and sends, for its consideration, the reports of indications of infringement respective, to the IGCC – sent to the IGCC, the result of its evaluation, and specifically what refers to the present PAS;
16. That, it must be kept in mind that the
procedures and legal forms with which the IGSC conducts its activity of oversight and/or supervision, which conclude with a report of indications of infringement, determine that its pronouncement or opinion on a specific topic of supervision must necessarily be an opinion on the merits of the matter – giving the possibility that even a decision is taken, such as, for example, the adoption of corrective measures –. Now, it must be specified that such opinion and the report of indications of infringement elaborated by the IGSC are not binding for the IGCC, as established in the second paragraph of article 9 of the Sanctions Regulation 2 ;
17. 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 (2) other organs or instances administrative of the SMV, functionally independent of each other and of this Office; first the IGSC which at its opportunity reported the indications of infringement and then the IGCC which, as a result of its evaluation, formulated the Office of Charges and the Report; and at this point of the PAS it corresponds to the Office of the SASCM, to issue a pronouncement

“Article 9.- PRELIMINARY INQUIRIES AS A CONSEQUENCE OF SUPERVISION ACTIONS The General Superintendencies of Supervision and the Adjunct Superintendence of Risks carry out preliminary inquiries of possible infractions to the regulations under the competence of the SMV that detect as part of their supervisory functions. When said organs conclude that there are sufficient indications of possible administrative infractions they send the corresponding reports to the General Superintendencies of Compliance, which determine whether it corresponds to initiate or not a administrative sanctioning procedure. If the case arises, the General Superintendencies of Compliance may carry out inspections or additional investigations of the indications reported. (…)”

PERU Ministry of Economy and Finance

SMV
Securities Market
Superintendence
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 authorship containing its decision with respect to the charges mentioned, being precise to indicate that by the nature of the same, as has been indicated previously, it will be a decision of single administrative instance for the charges subject of the present PAS;
18. That, next, it proceeds to evaluate the charge
imputed;
On voluntary remediation as an exemption from liability
19. That, as a prior matter, it must be mentioned that on
April 30, 2026, it was published, in the Official Journal “El Peruano”, the Supreme Decree No.
006-2026-JUS which approves the new Unified Text Ordered of Law No. 27444 General Administrative Procedure Law (hereinafter, TUO of the LPAG), which maintains the voluntary remediation as an exemption from liability in paragraph f) of article 236-A;
20. That, now, regarding this particular, the Issuer
maintains that it would have complied with the requirements required by the referred exemption from liability; however, it corresponds to indicate that paragraph c) of article 28 of the Sanctions Regulation establishes the following:
“Article 28.- Circumstances in which remediation does not apply as an exemption from liability Those not subject to remediation for the purposes of what is provided for in paragraph f) of article 27:
(…) c) The late or incomplete presentation, or the non-presentation of material facts, financial information and annual reports.
(…);
21. That, in that sense, according to the normative
indicated, it does not correspond to exempt the Issuer from liability, due to the fact that, according to paragraph c) of article 28 of the Sanctions Regulation, voluntary remediation does not apply as an exemption from liability in cases of late presentation of material facts, among others;
22. That, with respect to what was manifested by the Issuer,
regarding that it remediated the infraction subject of charge, it must be pointed out that, although article 236-A of the TUO of the LPAG does not establish limitations on the facts that can be remediated, there are certain infringing conduct whose consequences are not possible to repair. Likewise, it must be taken into consideration that the TUO of the LPAG does not expressly state that every administrative infraction can be subject of remediation, since, if that were the case, it would seriously affect the compliance of sectoral norms, through which the State is organized and functions;
23. That, in that sense, the Sanctions Regulation
has established, based on criteria of protection of the legal good protected by the TUO of the LMV, non-compliance that are not subject to remediation, such as the case of the infraction in mention, since it is not possible to repair the consequences or the effects of the non-compliance in the timely presentation of material facts, given the nature of the infringing conduct;
24. That, in that sense, in the case in particular it
evidences the lateness of the presentation of the material fact referred to the

PERU Ministry of Economy and Finance

SMV
Superintendency of Securities Market
Electronically signed document within the framework of Law N° 27269, Law on Digital Signatures and Certificates, its Regulations and amendments. The integrity of the document and the authorship approval, by Board Meeting on October 22, 2025, of the hiring of the auditing firm Ernst & Young Consultores S.C.R.L.;

On the application of mitigating criteria for the infraction and criteria for grading infractions

25. That, regarding the mitigating factor of recognition of the infraction, the Issuer expressly indicated that "(...) through this document RELAPASAA expressly and in writing recognizes its administrative responsibility in relation to the Imputed Fact; the General Intendency should proceed with the grading of the corresponding sanction, in accordance with the Law";

26. That, in this sense, the Issuer having submitted its defense within the period granted for the submission of defenses, it should be indicated that the voluntary declaration of recognition of the infraction by the Issuer is considered a mitigating condition of responsibility, so that when the applicable sanction is a fine, it is reduced by fifty percent (50%) if the recognition is submitted within the period granted for submitting defenses, in accordance with numeral 1 of literal a) of article 26 of the Sanctions Regulations, consistent with literal a) of numeral 2 of article 236-A of the TUO of the LPAG, which will be considered at the time of determining the sanction;

27. That, on the other hand, regarding the mitigating factor of the offender's contribution to the clarification of the infraction, the Issuer indicated that "(...) it has at all times shown full willingness to contribute to the regularization of the submission of the Important Event, since it complied with the submission without being required by the SMV";

28. That, however, it should be noted that, although the Issuer complied with the request for information made by the IGSC, this did not constitute a contribution to the clarification of the facts. Likewise, the information provided was limited to explaining its error already noticed by the authority, without having provided new or decisive information that could not have been obtained by the SMV through its supervisory powers;

29. That, in this sense, compliance with information requirements and the explanation of the origin of the untimely communication, by themselves, do not constitute the assumption of effective contribution to the clarification of the infraction required by literal b) of article 26 of the Sanctions Regulations, so it is not appropriate to apply the referred mitigating factor in the present case;

30. That, finally, what was stated by the Issuer regarding the sanction criteria will be evaluated in the section on the determination of the sanction;

V. DETERMINATION OF THE SANCTION

31. That, for the purpose of determining possible sanctions, infractions for communicating important events untimely should be noted that, in accordance with the provisions of subsection 3.1 of numeral 3 of Annex I of the Sanctions Regulations, it states that it constitutes a minor infraction:

"Submitting outside the established period, or doing so incompletely, or without observing the technical specifications approved by the SMV or without communicating the approval by

PERU Ministry of Economy and Finance

SMV
Superintendency of Securities Market
Electronically signed document within the framework of Law N° 27269, Law on Digital Signatures and Certificates, its Regulations and amendments. The integrity of the document and the authorship
part of the corresponding corporate body, to the SMV, to the Stock Exchange, to the entity in charge of the centralized negotiation mechanism or to any other entity or subject of the securities market, the individual or consolidated audited financial information, the individual or consolidated interim financial statements, management report, special audit report, important events and, annual reports." (Underline added);

32. That, in accordance with the provisions of article 35 of the Sanctions Regulations, these infractions must be sanctioned with a warning or a fine not less than one (1) UIT and up to the limit of twenty-five (25) UIT;

5.1. Sanction criteria

33. That, having determined that the Issuer has incurred in the commission of the imputed infraction, it is appropriate to evaluate the sanction in accordance with article 25 of the Sanctions Regulations, consistent with numeral 3) of article 230 of the TUO of the LPAG and article 344 of the TUO of the LMV, which develop the sanction grading criteria: (i) the issuer's sanction antecedents, (ii) recidivism, (iii) the circumstances of the commission of the infraction, (iv) the economic damage caused and its repercussions on the market, (v) the illicit benefit resulting from the commission of the infraction, (vi) the probability of detection of the infraction, (vii) the severity of the damage to public interest and/or protected legal good and (viii) the existence or not of intentionality in the offender's conduct;

34. That, regarding the severity of the damage to public interest and/or protected legal good, the timely submission of important events aims to allow investors to make adequately informed investment decisions. In this way, investors are protected and asymmetry in access to information is reduced, therefore, the protected legal good is the transparency of the securities market, which, when transgressed, affects public interest. In this sense, the infraction incurred by the Issuer affects the transparency of the securities market;

35. That, in relation to antecedents, literal a) of article 25 of the Sanctions Regulations states that the offender's antecedents are firm sanctions imposed by the SMV within four (04) years prior to the time of the commission of the infraction to be sanctioned. Likewise, the commission of the same infraction in the year prior to the infraction to be sanctioned is not considered an antecedent;

36. That, in the present case, one (01) sanction antecedent related to the Issuer has been identified, which is detailed below:

Table N° 1: Infraction antecedents of the Issuer

PERU Ministry of Economy and Finance

SMV
Superintendency of Securities Market
Electronically signed document within the framework of Law N° 27269, Law on Digital Signatures and Certificates, its Regulations and amendments. The integrity of the document and the authorship
37. That, regarding recidivism, it is considered as such for the commission of the same infractions those sanctions that have been imposed by the SMV for the commission of the same infraction to be sanctioned and that became final within one (01) year prior to the time of the commission of the infraction to be sanctioned;

38. That, in accordance with the foregoing, it has been verified that the Issuer has one (01) sanction resolution that would constitute recidivism for the infraction of untimely submission of important events, as shown in the following table:

Table N° 2: Recidivism of the Issuer

39. That, regarding the circumstances of the commission of the infraction, from the verification of the information disseminated by the issuers on the SMV Institutional Page, it is noted that the untimely communication of the important event related to the approval, by Board Meeting on October 22, 2025, of the hiring of the auditing firm Ernst & Young Consultores S.C.R.L. Said agreement should have been communicated on the same day of its approval, however, the communication was made with a delay of eight (08) calendar days;

40. That, regarding the economic damage caused and its repercussions on the market, it has not been evidenced that the non-compliance subject to the charge has produced quantifiable damage, understood as economic damage caused to one or more investors;

41. That, in relation to the illegally obtained benefit, it has not been accredited that the infraction incurred by the Issuer has generated an illegal benefit;

42. That, regarding the probability of detection of infractions, we must indicate that the fact subject to the charge is verified through the SMV's internal control systems, so it is considered that, for this type of non-compliance, the probability of detection is high and less complex, as it results from the SMV's supervisory work;

43. That, regarding the severity of the damage to public interest and/or protected legal good, the timely submission of important events aims to allow investors to make adequately informed investment decisions. In this way, investors are protected and asymmetry in access to information is reduced, therefore, the protected legal good is the transparency of the securities market, which, when transgressed, affects public interest. In this sense, the infraction incurred by the Issuer affects the transparency of the securities market;

44. That, regarding the existence or not of intentionality in the offender's conduct, it has not been evidenced that the Issuer acted intentionally or fraudulently when incurring in the aforementioned infraction;

45. That, from the evaluation carried out on the Sanction Criteria by this Deputy Superintendency and considering what was analyzed in the Report, it is appropriate to impose a fine of 2.86 UIT 3 equivalent to S/ 15,311.70 (Fifteen Thousand Three Hundred Eleven and 70/100 Soles) for having communicated untimely the important event referred to the approval, by Board Meeting on October 22, 2025, of the hiring of the auditing firm Ernst & Young Consultores S.C.R.L.;

5.2. Recognition of responsibility

46. That, the Issuer stated in its defense that it recognized having incurred in the infraction subject to analysis in this PAS, so, in application of the fifty percent (50%) reduction by virtue of the recognition of responsibility, it is appropriate to apply to the Issuer a total fine of 1.43 UIT equivalent to S/ 7,655.85 (Seven Thousand Six Hundred Fifty-Five and 85/100 Soles), and;

In accordance with the provisions of numerals 14 and 36 of article 43 of the Regulations on Organization and Functions of the Superintendency of Securities Market – SMV, approved by Supreme Decree N° 216-2011-EF;

RESOLVES:

Article 1.- Declare that Refinería La Pampilla S.A.A. has incurred in one (01) minor infraction typified in numeral 3, subsection 3.1 of Annex I of the Sanctions Regulations, approved by Resolution SMV N° 035-2018-SMV/01, for not having complied with submitting within the established period the important event referred to the approval, by Board Meeting on October 22, 2025, of the hiring of the auditing firm Ernst & Young Consultores S.C.R.L. to issue the report required by the penultimate paragraph of subsection c) of article 51 of the Consolidated Text of the Securities Market Law, Legislative Decree N° 861, approved by Supreme Decree N° 020-2023-EF-11.

Article 2.- Sanction Refinería La Pampilla S.A.A. with a fine of 1.43 UIT equivalent to S/ 7,655.85 (Seven Thousand Six Hundred Fifty-Five and 85/100 Soles; as provided in article 1 of this Resolution.

Article 3.- This Resolution does not exhaust the administrative process, and may be challenged before this Deputy Superintendency of Market Conduct Supervision by filing a reconsideration appeal, an administrative appeal recognized in article 207 of the Consolidated Text of Law N° 27444, General Administrative Procedure Law, approved by Supreme Decree N° 006-2026-JUS, within fifteen (15) business days counted from the day following its notification, as it is a single administrative instance procedure. In case this Resolution is not challenged, it may avail itself of the corresponding sanction reduction regime.

Article 4.- In case this Resolution is not subject to challenge, it must be published on the "SMV Institutional Page on the Peruvian State's Single Digital Platform for Citizen Orientation (www.gob.pe/smv), in observance of the provisions of numeral 1 of article 7 of the "Policy on dissemination of regulatory projects, general legal norms, early agenda and other administrative acts of the SMV", approved by Resolution SMV N° 014-2014-SMV/01, and by the provisions of the last paragraph of article 14 of the Sanctions Regulations, approved by Resolution SMV N° 035-2018-SMV/01.

Article 5.- Transcribe this Resolution to Refinería La Pampilla S.A.A.

Register, communicate and publish.

Carlos Rivero Zevallos
Deputy Superintendent
Deputy Superintendency of Market Conduct Supervision

3 Supreme Decree N° 260-2024-EF set the UIT for fiscal year 2024 at S/ 5,350.00.

PERU Ministry of Economy and Finance

SMV
Superintendency of Securities Market
Electronically signed document within the framework of Law N° 27269, Law on Digital Signatures and Certificates, its Regulations and amendments. The integrity of the document and the authorship