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Superintendency Resolution Adjunta SMV No. 041-2024-SMV/11

Lima, 12 July 2024

Summary: To sanction Centenario Desarrollo Urbano S.A.C. with a total fine of 1.5 UIT for having committed one (1) minor infringement typified in item 3.1, subsection 3 of Annex I of the Sanctions Regulations

Regulated Entity : CENTENARIO DESARROLLO URBANO S.A.C.
Subject
:
Single-instance Administrative Sanctioning Procedure Main Type : Item 3.1 of subsection 3 of Annex I of the Sanctions Regulations MINOR INFRINGEMENT Case File No. : 2024008439

SEEN:

The Acting Deputy Superintendent of Market Conduct Supervision

Administrative case file No. 2024008439 of the administrative sanctioning procedure initiated by the General Directorate of Conduct Compliance of the Superintendency of the Securities Market – SMV (hereinafter, the IGCC), against Centenario Desarrollo Urbano S.A.C. (hereinafter, the Issuer); as well as Report No. 510-2024-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) to which this case refers— has brought to the attention of the Superintendency Adjunta of Market Conduct Supervision of the SMV (hereinafter, SASCM) the PAS of administrative case file No. 2024008439 in order for it to issue a decision as the single-instance sanctioning body in the case of infringements regarding timeliness in the

PERU Ministry of Economy and Finance
SMV
Superintendency of the Securities
Market
“Decade of Equal Opportunities for Women and Men” "Year of the Bicentennial, of the consolidation of our Independence, and of the commemoration of the heroic battles of Junín and Ayacucho"

presentation of periodic and eventual information. In this way, the SASCM assumes competence in observance of the exercise of the supervision function and the sanctioning power of the Superintendency of the Securities Market – SMV, established by the Consolidated Text of its Organic Law, Supreme Decree No. 26126 (hereinafter, LOSMV), and the Single Ordered Text of the Securities Market Law, Legislative Decree No. 861, approved by Supreme Decree No. 020-2023-EF-1 1 (hereinafter, TUO LMV); as well as by the provisions of the Sanctions Regulations, approved by SMV Resolution No. 035-2018-SMV/01 (hereinafter, Sanctions Regulations); and, in articles 42 and 43 of the Regulations on Organization and Functions of the Superintendency of the Securities Market – SMV, approved by Supreme Decree No. 216-2011-EF (hereinafter, ROF-SMV), in the sense that it is a specific function of the SASCM to impose sanctions in a single administrative instance for the commission of infringements whose compliance control corresponds to the aforementioned Deputy Superintendency. Likewise, the SASCM has the powers to issue corrective measures aimed at reversing the situation altered by the commission of the infringement;

II. Facts, charges and defenses of the Regulated Entity

2.1 Facts

2. That it was determined that the Issuer failed to timely send a material fact, in accordance with the provisions of the current regulations of the Superintendency of the Securities Market – SMV;

2.2 Charge

3. That, as a result of said evaluation, by means of Letter No. 851-2024-SMV/11.2 dated 08 March 2024 (hereinafter, Charge Letter), one (1) charge was formulated against the Issuer for out-of-time communication of the material fact referred to the agreement of the General Shareholders' Meeting of 31 March 2023, in which its auditing firm was designated for the 2023 fiscal year, a fact that should have been communicated on that same day; however, it was communicated out of time on 01 June 20232;

4. That this non-compliance is typified in item 3.1 of subsection 3 of Annex I of the Sanctions Regulations;

2.3 Defenses

5. That, by means of a document dated 22 March 2024, the Issuer submitted its defenses regarding the charge formulated against it;

6. That, in the submitted defenses, the Issuer acknowledges the commission of the infringement, in accordance with the provisions of letter a) of article 26 of the Sanctions Regulations;

7. That, however, the Issuer requests that the sanction of a warning be applied to it and, to that end, develops the corresponding criteria

[1] By means of Supreme Decree No. 020-2023-EF, published on 10 February 2023 in the Official Gazette El Peruano, the Single Ordered Text of the Securities Market Law, Legislative Decree No. 861, was approved.

[2] Case File No. 2023024866

for said sanction:

(i) Regarding the impact on transparency in the market, the Issuer indicates that this has been minimal, given that, despite having a commercial paper issuance program, to date, it has not carried out any issuance. Likewise, the Issuer adds that it corrected on its own the material fact regarding the designation of its auditing firm and would have done so as soon as it became aware and within the deadline established in the “SMV Schedule”.

(ii) In relation to the absence of specific harm caused to investors, the Issuer indicates that, since it has no investors who could be affected or harmed by the conduct underlying the breach, no specific harm in this regard existed. The Issuer also indicates that its breach "was no more than 60 days" and reiterates that the material fact was communicated within the period established in the "SMV Schedule".

(iii) With respect to prior record and recidivism, the Issuer indicates that it has no prior record or recidivism.

(iv) Finally, the Issuer indicates that it has not obtained any economic benefit from the conduct alleged, nor did it have any intention in committing the infringing conduct;

8. That, by Supreme Decree No. 004-2019-JUS, the Single Consolidated Text of the General Administrative Procedure Act – Act No. 27444 (hereinafter, the TUO of the LPAG) was approved, which contains common rules for the actions of the State's administrative function and regulates all administrative procedures carried out in entities, including special procedures. Likewise, item 3) of Article 248 of the TUO of the LPAG sets out the criteria relating to the gradation of the sanction: (a) The unlawful benefit resulting from the commission of the infringement, (b) The probability of detection of the infringement, (c) The seriousness of the harm to the public interest and/or the protected legal asset, (d) The economic harm caused, (e) Recidivism, for the commission of the same infringement within a period of one (1) year from the time the resolution sanctioning the first infringement became final, (f) The circumstances of the commission of the infringement; and, (g) The existence or not of intent in the conduct of the infringer;

9. That the charge brought and the criteria relating to the gradation of the sanction have been subject to evaluation in the Report, which has been made known to the SASCM;

10. That, in compliance with the provisions of item 5 of Article 255 of the TUO of the LPAG, by means of Official Letter No. 2237-2024-SMV/11.2 dated 22 May 2024, the Report was sent to the Issuer so that it may submit its allegations within five (05) business days of notification, which were submitted on 31 May 204, stating that they submit to the content of the Report, acknowledging the amount of the proposed fine;

III. Issues to be determined

11. That, in the present PAS, the following must be determined:

(i) Whether or not the Issuer committed the infringement indicated in the Charge Letter and Report.

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(ii) Whether or not a sanction should be imposed on the Issuer;

IV. ANALYSIS

4.1 Applicable Regulations

12. That, regarding the obligation to communicate material facts, article 30 of the TUO of the LMV states: "The registration of a certain security or issuance program entails for its issuer the obligation to inform the SMV and, where appropriate, the respective stock exchange or entity responsible for the conduct of the centralized mechanism, of the material facts, including ongoing negotiations, about itself, the security and the offer made thereof, as well as to disclose such facts in a truthful, sufficient and timely manner. The information must be provided to said institutions and disclosed as soon as the fact occurs or the issuer becomes aware of it, as the case may be". (Underline added);

13. That, in this sense, numeral 9.1 of article 9 of the Regulation of Material Facts and Reserved Information, approved by SMV Resolution No. 005-2014-SMV/01 (Regulation of Material Facts), states: "The Issuer must report its material fact as soon as such fact occurs or the Issuer becomes aware of it, and in no case beyond the day on which it has occurred or has been known. (...)";

14. That, according to numeral 11 of Annex 1 of the Regulation of Material Facts, the following may qualify as material facts: "11. Appointment and termination of contract with its audit firm." (Underline added)";

15. For the purposes of determining the possible sanction, this infraction is typified in subsection 3.1 of numeral 3 of Annex I of the Sanctions Regulation, which states that it constitutes a minor infraction: "Submit outside the established period, or do so incompletely, or, without observing the technical specifications approved by the SMV or without communicating the approval by the corresponding corporate body, to the SMV, the Stock Exchange, the entity in charge of the centralized negotiation mechanism or any other entity or subject of the securities market, the audited individual or consolidated financial information, the individual or consolidated interim financial statements, management report, special audit report, material facts and annual reports." (Underline added);

16. That, according to article 35 of the Sanctions Regulation, minor infractions are punishable with a warning or a fine of not less than one (1) UIT and up to twenty-five (25) UIT;

4.2 Evaluation of the case

17. That, the Issuer acknowledges its responsibility expressly and in writing for the commission of the infraction referring to the late submission of the material fact regarding the agreement of the General Shareholders' Meeting of 31 March 2023, in which its audit firm was appointed for the 2023 fiscal year, a fact that should have been communicated that same day; however, it was communicated late on 01 June 2023;

18. That, the Issuer makes the acknowledgment of

liability pursuant to the provisions of item a) of numeral 2 of article 257 of the TUO of the LPAG and item a) of article 26 of the Sanctions Regulations;

19. That, notwithstanding the foregoing, the Issuer requests that certain arguments be taken into account for the evaluation of the sanction criteria that will determine the corresponding sanction. In this regard, the Issuer's arguments will be collected and evaluated in the section where the sanction criteria are evaluated in detail;

20. That, in addition to its arguments regarding the sanction criteria, the Issuer sets forth certain ideas that it is pertinent to clarify at this point. En tal sentido, el Emisor sostiene que subsanó de modo propio la comunicación del hecho de importancia respecto a la designación de su sociedad auditora, al señalar: “(…) al haberse subsanado motu proprio el reporte del hecho de importancia relacionado con la designación del auditor externo, tan pronto como se tuvo conocimiento de que no se había hecho y, además dentro de la “fecha límite” conferida en el Cronograma, (…)”

21. That, in this regard, it is pertinent to indicate that material facts are not subject to cure, in accordance with letter c) of article 28 of the Sanctions Regulations3, therefore arguing the possibility of cure is incorrect. Likewise, it must be added that the obligation to report a material fact must be fulfilled as soon as the fact occurs or when the Issuer becomes aware of the fact, that is, in the specific case, given that the Issuer, at its General Shareholders' Meeting of 31 March 2023, approved the appointment of its external auditors; this decision should have been reported to the market on the same day;

22. That, a second point to clarify is that, erroneously, the Issuer maintains that its material fact of 01 June 2023 was reported within the period established in the “SMV Timeline”. In doing so, the Issuer confuses the obligation to timely report material facts with the obligation that was in article 384 of the Financial Information Regulations, approved by CONASEV Resolution N° 103-99-EF/94.10 (hereinafter, the Financial Information Regulations), which stated -before its amendment-

[3] “Article 28.- CIRCUMSTANCES IN WHICH CURE DOES NOT APPLY AS A GROUND FOR EXEMPTION FROM LIABILITY The cure prior to the notification of the charges shall not be considered as a ground for exemption from liability when a communication has been issued requiring compliance with the obligation. They cannot be remedied for the purposes of the provisions of literal f) of article 27: (…) c) The late or incomplete presentation, or the non-presentation of material facts, financial information and annual reports. (…).”

[4] Article 38 of the Financial Information Regulation, approved by CONASEV Resolution No. 103-99-EF/94.10, as amended by the Fifth Complementary Amending Provision of SMV Resolution No. 013-2023-SMV/01, published on 10 December 2023, states: “Article 38.- Obligations related to the external audit Companies obliged to submit audited financial information must report, as a material fact, the appointment of their independent auditors. Issuing companies whose appointment of independent auditors depends on the Contraloría General de la República must report as a material fact the appointment of their independent auditors at the time they become aware of said appointment, as well as the date on which the audit work will begin. The work plan of the independent auditors may be requested by the SMV from the auditing firms.”

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that companies obliged to submit audited financial information had to report as a material fact the appointment of their independent auditors no later than 30 June of each year;

23. That, the breach of the obligation of article 38 of the Financial Information Regulation was sanctioned with the infraction type 3.6 of subsection 3 of Annex 1 of the Sanctions Regulation and is not the object of this PAS, therefore stating that the Issuer made the appointment before 30 June (or within the period established in the “SMV Schedule”, as the Issuer points out), has no relevance whatsoever in this PAS in which only the infraction for late reporting of a material fact is evaluated;

24. That, in accordance with the foregoing, having verified that the Issuer has incurred in one (1) conduct constituting an infraction, by not having timely submitted the material fact detailed above; the sanction that would be applicable shall be determined, for which purpose the principle of reasonableness and the sanction criteria contained in article 344 of the TUO of the LMV, in article 25 of the Sanctions Regulation and the provisions of numeral 3 of article 248 of the TUO of the LPAG shall be taken into consideration, which will be developed in the following section;

V. Determination of the Sanction

25. That, on this matter, the failure to timely present material events is classified in item 3.1 of paragraph 3 of Annex I of the Sanctions Regulation, which states that it constitutes a minor infraction: “Presenting outside the established deadline, or doing so incompletely, or, without observing the technical specifications approved by the SMV or without communicating the approval by the corresponding corporate body, to the SMV, to the Exchange, to the entity in charge of the centralized negotiation mechanism or to any other entity or subject of the securities market, the audited individual or consolidated financial information, the individual or consolidated interim financial statements, management report, special audit report, material events and annual reports.” (Underline added);

26. That, in relation to the sanction, in accordance with article 35 of the Sanctions Regulation, a minor infraction is punishable with a warning or a fine of not less than one (1) UIT and up to twenty-five (25) UIT;

27. That, in order to analyze the corresponding sanction for this type of non-compliance, the Criteria applicable to the administrative sanctioning procedure for non-compliance with the rules regulating the submission of periodic or occasional information, approved by SMV Resolution No. 006-2012-SMV/01, (hereinafter, Special Sanction Criteria) in force at the time of the commission of the infraction subject of this PAS, must be taken into account;

28. That, however, it must be indicated that through article 1 of Resolution No. 007-2023-SMV/01 published on 08 September 2023, the Graduality Regime of Sanctions for late submission of financial information, annual report and material events (hereinafter, New Graduality Regime of Sanctions) was approved, whose article 4 provided for its validity as of 01 January 2024; and article 2 of the referred Resolution repealed the Special Sanction Criteria;

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29. That, in view of the foregoing, it is appropriate to analyze whether in the present case the provisions of the New Graduality Regime of Sanctions should be applied by virtue of the Principle of Favorable Retroactivity, established in item 5 of article 248 of the TUO of the LPAG, which states that: “(…) the sanctioning provisions in force at the time the administered party incurs the conduct to be sanctioned are applicable, unless the subsequent ones are more favorable to it”;

5.1 Special Sanction Criteria

30. That, in that sense, the aforementioned rules are consistent with the provisions of item 3) of article 248 of the TUO of the LPAG and article 344 of the TUO of the LMV, which develop the criteria for the graduation of the sanction: (i) the sanction history of the issuer, (ii) recidivism, (iii) the circumstances of the commission of the infraction, (iv) the economic damage caused and its impact 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 the public interest and/or protected legal interest and (viii) the existence or not of intentionality in the conduct of the offender;

31. That, in relation to the severity of the damage to the public interest and/or protected legal interest, it must be indicated that the timely submission of periodic or occasional information has the purpose of allowing investors to adopt investment decisions in an adequately informed manner. In this way, investors are protected and the asymmetry in access to information is reduced; therefore, the protected legal interest is the transparency of the securities market, which, when transgressed, affects the public interest. It should be noted that the Issuer has stated that its non-compliance would have had a minimal impact on market transparency, since, despite having a commercial paper issuance program, to date, it has not carried out any issuance.

That, it is appropriate to remind the Issuer that its status as a participant in the securities market is that of an Issuer since it has shares registered in the Public Registry of the Securities Market - RPMV and as such is subject to the rules applicable to issuers of the securities market. Furthermore, the rules applicable in this administrative sanctioning procedure do not contemplate any distinction or flexibilization for issuers that have not issued debt securities with respect to those that have, so the rules must be applied to all issuers equally;

32. That, with respect to the sanction history, literal a) of article 25 of the Sanctions Regulation establishes that these are the final sanctions imposed by the Superintendency of the Securities Market – SMV within the period of four (4) years prior to the commission of the infraction to be sanctioned; and specifies that the commission of the same infraction in the year prior to the infraction to be sanctioned is not considered as a history; In application of said criterion, it has been verified that the Issuer does not have a sanction history, according to what was evaluated in the Report;

33. That, in relation to recidivism for the commission of the same infraction, literal b) of article 25 of the Sanctions Regulation establishes that the final sanction imposed by the Superintendency of the Securities Market – SMV within the period of one (01) year prior to the commission of the infraction to be sanctioned is taken into account. In application of said criterion, it is

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has verified that there is no recurrence on the part of the Issuer with respect to the infringement relating to the late submission of material facts;

34. That, in relation to the circumstances of the infringement, it has been verified that the Issuer submitted its material fact relating to the agreement on the appointment of its auditing firm for the 2023 financial year, a fact that should have been communicated on that same day; however, it was communicated out of time on 01 June 2023, that is, with a delay of sixty-two (62) calendar days;

35. That, in this regard, it is necessary to indicate that the Issuer stated that its non-compliance "was no more than 60 days" and that the material fact was made within the period established in the "SMV Schedule". In this regard, it is necessary to reiterate to the Issuer what is stated in article 30 of the TUO of the LMV and in item 9.1 of article 9 of the Material Facts Regulations transcribed above, provisions which clearly state that the obligation of the Issuer, as is the case of the Issuer, since its shares are registered in the RPMV, is to disclose its material facts as soon as such fact occurs or the Issuer becomes aware of it;

36. That, consequently, when the Issuer states that its breach "was no more than 60 days," this shows that the Issuer is not internalizing the rules of the securities market, since it should know that breaches in the filing of material facts and financial information are important obligations that safeguard the transparency and proper functioning of said market. Being so, the breach under evaluation warrants a monetary fine penalty, since the market has been deprived of important information, such as the designation of an Issuer's audit firm for more than sixty (60) days. Additionally, the Issuer erroneously added that it had properly remedied the communication of the material fact regarding the designation of its audit firm;

37. That, it must be reiterated that material facts are not subject to remediation, in accordance with letter c) of Article 28 of the Sanctions Regulation transcribed above, so arguing the possibility of remediation is incorrect;

38. That, regarding the existence of economic harm caused and market impact, it has not been shown that the breach produced quantifiable harm, understood as economic damage caused to one or several investors;

39. That, regarding the illicit benefit resulting from the commission of the infringement, in the present case, there are not sufficient elements to indicate that the Issuer obtained an illegal benefit as a consequence of the commission of the aforementioned infringement;

40. That, regarding the criterion of probability of detection of the infraction, it must be noted that the failure to timely present periodic or eventual information is verified through internal control systems, so the probability of detection is high;

41. That, regarding the existence or not of intentionality in the conduct of the offender, it is considered that the actions of the Issuer

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was not intentional, but negligent, by not having acted with due diligence in complying with its obligation to timely present its material facts.

It should be noted that if the existence of intentional actions by the Issuer had been proven, we would have to point out that aggravating circumstances were proven in the procedure, which would allow the Deputy Superintendency to increase the fine up to the maximum permitted by the corresponding law, that is, up to 25 UIT, as it is a minor infraction. As this is not the case, it will not be increased up to that amount;

42. That, in addition to the foregoing, it should be noted that in this PAS it has been verified that no exempting circumstances have been presented, but there are mitigating circumstances of responsibility established in article 2575 of the TUO of the LPAG, in accordance with article 266 of the Sanctions Regulation;

5.2. Evaluation of the Principle of Favorable Retroactivity

43. That, as indicated above, since the New Regime of Gradualness of Sanctions entered into force on 1 January 2024 and the PAS is in process (sanctioning phase); it is appropriate to analyze whether this new regulation is more beneficial or not for the determination of the sanction to be imposed, by virtue of the principle of favorable retroactivity, established in numeral 5 of article 248 of the TUO of the LPAG;

44. That, from the comparison of the provisions in numeral (iv) of subsection 4.2 of the Special Sanction Criteria and numeral 6.2 of article 6 of the New Gradualness Regime (which determine the fine by quantifying the base in UIT and for each day of delay), it is observed that a lower amount to be sanctioned is obtained with the application of the Special Sanction Criteria, as detailed in the Annex of the IGCC Report;

45. That, in this sense, from the review of the Criteria

[5] “Article 257.- Exemptions and mitigating circumstances of liability for infractions 1.- The following constitute conditions exempting liability for infractions: a) Duly proven fortuitous event or force majeure. b) Acting in compliance with a legal duty or the legitimate exercise of the right of defense. c) Mental incapacity duly proven by the competent authority, provided that it affects the ability to understand the infraction. d) The mandatory order of a competent authority, issued in the exercise of its functions. e) The error induced by the Administration or by a confusing or illegal administrative provision. f) The voluntary correction by the possible sanctioned party of the act or omission imputed as constituting an administrative infraction, prior to the notification of the imputation of charges referred to in subsection 3) of article 235. 2.- The following constitute mitigating conditions of liability for infractions: a) If, once an administrative sanctioning procedure has been initiated, the offender acknowledges its responsibility expressly and in writing. In cases where the applicable sanction is a fine, it is reduced to an amount not less than half of its amount. b) Others established by special rule.”

[6] “Article 26.- MITIGATING CIRCUMSTANCES OF LIABILITY FOR INFRACTIONS The following constitute mitigating conditions of liability for infractions: a) Acknowledgment of responsibility by the offender expressly and in writing, once the administrative sanctioning procedure has been initiated. When the applicable sanction is a fine, it is reduced, taking into account the following: (…) 3. If the acknowledgment is submitted after the expiration of the term granted to submit arguments to the instruction report and up to before the issuance of the sanction resolution, the reduction amount shall be ten percent (10%).”

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Special Sanction Criteria and the New Graduality Regime, it is observed that for the infraction subject to charges, the graduation with the Special Sanction Criteria, in force at the time of the commission of the infraction, is more favorable, as detailed in the Report, so it is appropriate to impose on the Issuer a fine of 3 UIT7, equivalent to S/ 14,850.00 (Fourteen Thousand Eight Hundred Fifty and 00/100 Soles);

5.3. Application of the acknowledgment of responsibility

46. That, taking into account the acknowledgment of responsibility expressly and in writing, within the term granted for the submission of defenses, made by the Issuer and consistent with the provisions of numeral 1 of subsection a) of article 26 of the Sanctions Regulation; this Deputy Superintendency is of the opinion of applying the reduction of the fine by up to 50% and therefore, imposing on the Issuer a total fine of 1.5 UIT equivalent to 7,425.00 (Seven Thousand Four Hundred Twenty-Five and 00/100 Soles);

47. That, the Issuer is reminded that firm resolutions of sanctions imposed by competent authorities must be reported as a material fact, within the framework of the provisions of article 5 of the Regulation of Material Facts, and;

In accordance with the provisions of numerals 14 and 36 of article 43 of the Regulation of Organization and Functions of the Superintendency of the Securities Market, approved by Supreme Decree No. 216-2011-EF;

RESOLVES:

Article 1.- Declare that Centenario Desarrollo Urbano S.A.C. has incurred in one (1) infraction of a minor nature typified in subsection 3.1 of numeral 3 of Annex I of the Sanctions Regulation, for the late communication of the material fact referring to the agreement of the General Shareholders' Meeting of 31 March 2023, in which its audit firm was appointed for fiscal year 2023, a fact that should have been communicated that same day; however, it was communicated late on 01 June 2023.

Article 2.- Sanction Centenario Desarrollo Urbano S.A.C. with a fine of 1.5 UIT equivalent to 7,425.00 (Seven Thousand Four Hundred Twenty-Five and 00/100 Soles), for the provisions of article 1 of this Resolution.

Article 3.- This Resolution does not exhaust the administrative remedy, and it may be challenged before this Deputy Superintendency of Supervision of Market Conducts by filing a reconsideration appeal, an administrative appeal recognized in article 218 of the Single Ordered Text of the General Administrative Procedure Law – Law No. 27444, approved by Supreme Decree No. 004-2019-JUS, within a term of fifteen (15) business days counted from the day following its notification.

Article 4.- In the event that this Resolution is not subject to challenge, it must be published on the “Institutional Page of the SMV on the Single Digital Platform of the Peruvian State for Citizen Orientation

[7] Value of the UIT (2023): S/ 4 950 (Supreme Decree No. 309-2022-EF)

(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 SMV Resolution No. 014-2014-SMV/01, and by the provisions of the last paragraph of article 14 of the Sanctions Regulation, approved by SMV Resolution No. 035-2018-SMV/01.

Article 5.- Transcribe this Resolution to Centenario Desarrollo Urbano S.A.C.

Carlos Rivero Zevallos
Deputy Superintendent (e)
Deputy Superintendency of Supervision of Market Conducts

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