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Superintendency Resolution Adjunta SMV No. 053-2024-SMV/11

Lima, 19 August 2024

Summary: Sanction AI Inversiones Palo Alto S.A. with one (1) warning for having incurred one (1) infraction of a minor nature, classified in subsection 3.7 numeral 3 of Annex I of the Sanctions Regulations.

Administered : AI INVERSIONES PALO ALTO S.A.
Subject
: Administrative Sanctioning Procedure of double administrative instance Main Type : Subsection 3.7 of numeral 3 of Annex I of the Sanctions Regulations MINOR INFRACTION File No. : 2024007067

The Deputy Superintendent of Supervision of
Market Conduct

VIEWS:

Administrative file No. 2024007067, containing the administrative sanctioning procedure initiated by the General Intendancy of Conduct Compliance of the Superintendency of the Securities Market – SMV (hereinafter, the IGCC), against AI Inversiones Palo Alto S.A. (hereinafter, the Issuer); as well as Report No. 737-2024-SMV/11.2 (hereinafter, the Report), issued by the IGCC;

CONSIDERING:

I. FUNCTION AND COMPETENCE OF THE SASCM

1. That, the IGCC —instructing body of the administrative sanctioning procedures (hereinafter, the PAS) referred to in the present case—, has brought to the attention of the Deputy Superintendency of Supervision of Market Conduct of the SMV (hereinafter, SASCM), the PAS of administrative file No. 2024007067 in order for it to issue a decision as sanctioning body of first administrative instance in said PAS. Thus, the SASCM assumes competence in observance of the exercise of the supervision function and of the

sanctioning power of the Superintendency of the Securities Market - SMV established by the Single Concorded Text of its Organic Law, Legislative Decree No. 26126 (hereinafter, Organic Law of the SMV), and in the Single Ordered Text of the Securities Market Law, Legislative Decree No. 861, approved by Supreme Decree No. 020-2023-EF (hereinafter, TUO of the LMV); as well as by the provisions in the Sanctions Regulations, approved by SMV Resolution No. 035-2018-SMV/01 (hereinafter, Sanctions Regulations) and in articles 42 and 43 of the Regulations of Organization and Functions of the SMV, approved by Supreme Decree No. 216-2011-EF (hereinafter, ROF of the SMV), in the sense that it is a specific function of the SASCM to impose sanctions in first administrative instance for the commission of infractions whose compliance control according to its competences corresponds to said Deputy Superintendency. Likewise, the SASCM has the powers to issue corrective measures aimed at reverting the situation altered by the commission of the infraction;

II. FACTS, CHARGE, DEFENSES AND ALLEGATIONS

2.1 Fact

2. That, it was evaluated whether the Issuer complied with its obligation to present or keep updated the information about its Economic Group;

2.2 Charge

3. That, from the information about economic group published in the Economic Group section of the Institutional Page of the SMV it was observed that the Issuer sent on 11 January 2021 the Report on its Economic Group according to the Information Formats on Economic Group (File No. 2021001028), registering as of 30 November 2020 the concepts of total amount of assets and equity of its economic group;

4. That, on 31 March 2023 it sent to the SMV the Report of its Economic Group jointly with the Annual Report and Annual Individual Financial Statements of the 2022 fiscal year (File No. 2023014796), in which the same data of total assets and equity reported on 11 January 2021 with relation to the 2020 fiscal year were noted, data that appear in File No. 2021001028, as can be seen below:

5. That, as of the date of imputation of charges, the amount

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total assets and equity recorded in the Annual Individual Financial Statements for the 2022 fiscal year submitted in File No. 2023014796, were different or had varied in relation to the amount indicated in the Economic Group Report submitted together with said financial statements; therefore, having occurred a change in relation to section “II.a Entities that make up the Economic Group” the Issuer should have updated the information on its Economic Group and not record the same data presented as of 30 November 2020;

6. That, the commission of the infraction typified in subsection 3.7 of numeral 3 of Annex I of the Sanctions Regulation was imputed, which states: “Failure to submit to the SMV or, where applicable, to the entity responsible for a centralized trading mechanism, or failure to keep updated, the information on its Economic Group, as well as failure to inform the SMV, of share transfers that imply a change in the decision or control unit, or any modification of the data appearing in the Public Registry of the Securities Market, within the term or form established in the regulations on the matter.” (Underline added);

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

8. That, likewise, to date it is observed that the non-compliance indicated in the previous paragraphs has been corrected, given that on 08 April 2024 (File No. 2024015283) the Issuer submitted the Economic Group Report updating the concepts of total assets and equity as of 31 December 2022, in accordance with what was reported in the Annual Report and Annual Individual Financial Statements for the 2022 fiscal year;

2.3 Discharges and arguments

9. That, the Issuer, exercising its right of defense, by written submission of 08 April 2024, regarding the imputations formulated against it, the Issuer stated the following:

(i) It expressly, precisely and unconditionally acknowledges its administrative responsibility for the imputed infraction and submits to the pecuniary sanction that is imposed. Likewise, it requests that in application of the provisions of numeral 1 of literal a) of article 26 of the Sanctions Regulation, its acknowledgment be taken into consideration and a 50% reduction of the fine to be imposed be determined.

(ii) By letter of 8 April 2024, it has sent to the SMV the updated information on its economic group, remedying the imputed infraction. Likewise, it requests that in application of the provisions of subsection c) of article 26 of the Sanctions Regulation, the voluntary remediation of the infraction be taken into consideration and an additional reduction to the final fine to be imposed be determined.

(iii) Finally it stated that, according to the sanction criteria, it should be taken into account that the Issuer would not have obtained an illicit benefit as a result of the infraction, the probability of detection of the infraction would be high, it would not have generated harm to the public interest or any third party and there would also be no intentionality or benefit for itself or third parties in the imputed conduct, but rather the Issuer's non-compliance would be due to an error or omission, which would be evidenced in the acknowledgment and remediation of the infraction by the Issuer.

10. That, by Supreme Decree No. 004-2019-JUS, the Single Ordered Text of the General Administrative Procedure Law – Law No. 27444 (hereinafter, the TUO of the LPAG) was approved, which contains common rules for the actions of the administrative function of the State and regulates all administrative procedures developed in the entities, including special procedures. Likewise, numeral 3) of Article 248 of the TUO of the LPAG sets out the criteria relating to the gradation of the sanction: (a) The illicit benefit resulting from the commission of the infringement, (b) The probability of detection of the infringement, (c) The severity of the damage to the public interest and/or the protected legal asset, (d) The economic damage caused, (e) Recidivism, for the commission of the same infringement within a period of one (1) year from the date 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;

11. That, the charge formulated, the defenses 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;

12. That, in compliance with the provisions of numeral 5 of Article 255 of the TUO of the LPAG, by means of Letter N° 2931-2024-SMV/11 dated 09 July 2024, the Report was sent to the Issuer so that it may formulate its allegations within the period of five (05) business days; which were submitted on 17 July 2024 and in which the Issuer expressed its agreement with the Report;

III. ISSUES TO BE DETERMINED

13. That, in the present PAS it is necessary to determine the following:

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

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

IV. ANALYSIS

4.1 Applicable regulations

14. That, Article 13 of the TUO of the LMV establishes that: "(...) The legal entities registered in the Registry and the issuer of registered securities are obliged to submit the information that this law and other general provisions establish, being responsible for the veracity of such information.";

15. That, Article 7 of the Regulation on Indirect Ownership, Affiliation and Economic Groups, approved by Resolution SMV Nº 019-2015-SMV-01 and amendments (hereinafter, the Economic Group Regulation), establishes the definition of Economic Group:

"Article 7.- DEFINITION OF ECONOMIC GROUP An Economic Group is the set of entities, national or foreign, consisting of at least two entities, when one of them exercises control over the other(s) or when control over the entities corresponds to one or more natural persons acting as a decision-making unit. Natural persons do not form part of the economic group."

16. That, in relation to the obligation to submit Economic Group information, Article 8 of the Economic Group Regulation,

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provides:

"The issuers of securities registered in the Registry, the legal entities registered therein, and the EAFC are obliged to submit to the SMV and, where applicable, to the entity responsible for a centralized trading system in which such securities are registered, the reports on their Economic Group, in accordance with the formats established by the SMV. (Underlining added);

17. That, with respect to the timing of the submission of information, the second paragraph of Article 9 of the Economic Group Regulation establishes1:

"In the event that any change occurs in the information reported on the economic group, the information must be updated and submitted at the same time and jointly with the Annual Report of the obligated entity, unless the change qualifies as a matter of importance or a relevant event, in which case, without prejudice to the respective communication, the obligated entity must update such information within the following fifteen (15) calendar days. Such update must be carried out in accordance with the formats indicated in the first paragraph of the preceding article and, where applicable, must also be sent to the entity responsible for the centralized trading system in which the securities are registered." (Underlining added);

18. That, in relation to the manner of submitting Economic Group information, the foregoing in Articles 8 and 9 is pertinent, as well as the provisions of Article 10 of the Economic Group Regulation:

"Article 10.- TECHNICAL SPECIFICATIONS FOR SUBMITTING INFORMATION ON ECONOMIC GROUPS The information submitted to the SMV in compliance with the provisions of the preceding articles must observe the formats and technical specifications approved by the Superintendent of the Stock Market.";

19. That, in that sense, the obligated entities must comply with the updating and submission of information on their economic group through the Economic Group Report, in accordance with the Economic Group Information Formats, approved by Superintendent Resolution Nº 083-2016-SMV/02 dated 15 June 2016;

20. That, in this regard, section "II.a Entities that make up the Economic Group" of the Economic Group Information Formats,

[1] Second paragraph of Article 9 of the Economic Groups Regulation amended by Article 6 of Resolution SMV N° 019-2021-SMV/01, published on 30 October 2021, whose previous text is as follows: "In the event that any change occurs in the information reported on the economic group, the information must be updated no later than 31 March of the year following its occurrence, unless the change qualifies as a matter of importance or a relevant event, in which case, without prejudice to the respective communication as such, the obligated entity must update such information within the following fifteen (15) calendar days. Such update must be carried out in accordance with the formats indicated in the first paragraph of the preceding article and, where applicable, must also be sent to the entity responsible for the centralized trading mechanism in which the securities are registered.” (Underlining added).

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contains item “vii. Total value of assets and equity: Indicate amount and currency” and states “Note (1) Total Assets and Equity data will refer to the fiscal year immediately prior to the date of submission of the Economic Groups information”, therefore this information can be periodically updated each year with total assets and equity data for the fiscal year immediately prior to the date of submission;

4.2 Case assessment

21. That, in file No. 2024007067 containing the documentation of this PAS, it is noted that through Memorandum No. 3025-2023-SMV/11.1 of 24 July 2023 (File No. 2023031702), the General Directorate of Conduct Supervision (hereinafter, IGSC) —the body of the Superintendency of the Securities Market – SMV whose functions and powers include the supervision of compliance with the rules applicable to issuers with securities registered in the RPMV—, sent to the IGCC the result of its assessment, and specifically that related to this case;

22. That, it must be borne in mind that the procedures and legal forms with which the IGSC conducts its oversight and/or supervision activity and upon concluding it with a report of indications of infringement, determine that its statement or opinion on a specific supervision matter —which may even contain a decision, such as, for example, the adoption of corrective measures—, be an opinion on the merits of the matter; it must be specified that such opinion and the report of indications of infringement of the IGSC are not binding on the IGCC, as established in the second paragraph of article 9 of the Sanctions Regulations2 3;

23. That, in this way, it is established that in the assessment of the facts related to this PAS, two (2) other bodies of the Superintendency of the Securities Market – SMV, functionally independent of each other and of this Office, intervened and participated prior to the issuance of this resolution: first the IGSC, which on its part reported the indications of infringement through the aforementioned memorandum, and then the IGCC, which, as a result of its assessment, formulated the Charge Notice and the Report; and at this point of the PAS it corresponds

[2] In article 245 of the TUO of the LPAG, the following are indicated as forms or ways in which the oversight activity could conclude: 1) Certificate of conformity of the activity carried out by the administered party; 2) Recommendation of improvements or corrections to the activity carried out by the administered party; 3) The warning of the existence of non-compliances not susceptible to warranting the determination of administrative responsibilities; 4) The recommendation of the initiation of a procedure in order to determine the corresponding administrative responsibilities; 5) The adoption of corrective measures and 6) Other forms as established by special laws. 3 Article 9.- PRELIMINARY INQUIRIES AS A CONSEQUENCE OF SUPERVISION ACTIONS

[3] (…) When said bodies conclude that there are sufficient indications of possible administrative infractions, they forward the corresponding reports to the General Compliance Intendancies, which determine whether or not to initiate an administrative sanctioning procedure. If applicable, the General Compliance Intendancies may carry out additional inspections or investigations of the reported indications. In the case of possible infractions in the scope of the Regulation of the Financial Participatory Financing Activity and its Managing Companies, the preliminary inquiries are carried out by the General Intendancy of Research and Innovation, a dependency that, if there are sufficient indications of possible administrative infractions, will determine whether or not to initiate an administrative sanctioning procedure. (…).

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to the Office of the SASCM, to issue a pronouncement containing its decision regarding the aforementioned charge, it being necessary to indicate that by the nature thereof, it will be a first-instance administrative decision;

24. That, previously, it must be noted that by writing dated 08 April 2024, the Issuer presented its defenses regarding the imputations formulated against it in the present file;

25. That, in the present case, at the date of imputation of charges, the total amount of assets and equity recorded in the Annual Individual Financial Statements for the 2022 fiscal year presented in File No. 2023014796, were different or had varied in relation to the amount indicated in the Economic Group Report presented together with said financial statements; therefore, having a change in relation to the section “II.a Entities that make up the Economic Group” the Issuer should have updated the information on its Economic Group and not record the same data presented as of 30 November 2020;

26. That, on the matter, through its defense writing, the Issuer has expressly acknowledged its responsibility for the commission of the imputed infraction, by virtue of the provisions of literal a) of numeral 2 of article 257 of the TUO of the LPAG;

27. That, in that sense, it must be indicated that the voluntary declaration of acknowledgment of the infraction by the Issuer is deemed a mitigating condition of responsibility, so that when the applicable sanction is a fine, it is reduced by fifty percent (50%) if the acknowledgment is presented within the term granted to present defenses, in accordance with numeral 1 of literal a) of article 26 of the Sanctions Regulation4 , which will be considered at the time of determining the sanction;

28. That, likewise, according to what was indicated by the Issuer in its defense writing, it has been verified that on 08 April 2024 (File No. 2024015283) it has corrected the imputed infraction by presenting the updated Economic Group Report with the concepts of total amount of assets and equity as of 31 December 2022, in accordance with what was reported in the Annual Report and Annual Individual Financial Statements for the 2022 fiscal year; 29. That, consequently, having been accredited the

conduct constituting an infraction and determined the administrative responsibility of the Issuer, it corresponds to analyze the proposed sanction in accordance with the provisions of the principle of reasonableness and the sanction criteria, considering that the Issuer has acknowledged and corrected the infraction after the letter of charges; which will be evaluated in the section on determination of the sanction;

[4] “Article 26.- Mitigating circumstances for liability for infractions The following constitute mitigating circumstances for liability for infractions: a) Express written acknowledgment of liability by the offender, once the administrative sanctioning procedure has been initiated. When the applicable sanction is a fine, it is reduced, taking into account the following: 1. If the acknowledgment of the infraction is submitted within the period granted for the submission of defenses, the reduction amount shall be fifty percent (50%). (…)

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V. DETERMINATION OF THE SANCTION

30. That, having determined the existence of administrative liability on the part of the Issuer, for the commission of one (1) infraction classified in subsection 3.7 of numeral 3 of Annex I of the Sanctions Regulations, which states that the following constitutes a minor infraction:

“Failure to submit to the SMV or, where applicable, to the entity responsible for a centralized negotiation mechanism, or failure to keep updated, the information regarding its Economic Group, as well as failure to inform the SMV of share transfers that imply a change in the decision-making or control unit, or any modification of the data appearing in the Public Registry of the Securities Market, within the period or in the manner established in the relevant regulations.” (Underline added);

31. That, in accordance with Article 35 of the Sanctions Regulations, said infraction is punishable by a warning or a fine of no less than one (01) UIT and up to twenty-five (25) UIT;

32. That, in that sense, it is appropriate to determine the sanction to be imposed on the Issuer considering the sanction criteria established in Article 344 of the TUO of the LMV, numeral 3) of Article 248 of the TUO of the LPAG and the provisions of Article 25 of the Sanctions Regulations, which develop the criteria for grading the sanction, these being: (i) the issuer's sanction record, (ii) recidivism, (iii) the circumstances of the commission of the infraction, (iv) the economic harm 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 harm to the public interest and/or protected legal interest and (viii) the existence or not of intent in the offender's conduct;

33. That, in relation to the severity of the harm to the public interest and/or protected legal interest, it is relevant to note that with regard to the severity of the harm to the public interest and/or protected legal interest, it should be indicated that the timely submission of the Economic Group Report by issuers of securities registered in the Public Registry of the Securities Market constitutes a fundamental obligation in the transparency of the securities market, so that market participants can make their investment decisions adequately informed. Therefore, although no severity of harm to the public interest is evidenced, the failure to comply with the obligation to inform the market within the deadlines on the part of issuers affects market transparency, which is considered a protected legal interest;

34. That, regarding the sanction record, subsection a) of Article 25 of the Sanctions Regulations establishes that these are final sanctions imposed by the Superintendency of the Securities Market – SMV within a period of four (4) years prior to the commission of the infraction to be sanctioned (in this case, March 31, 2023); notwithstanding this, it is clarified that the commission of the same infraction in the year prior to the infraction to be sanctioned is not considered as a record. In this regard, from the verification carried out in the SMV's Sanctions System, it has been determined that the Issuer has a sanction record, having been sanctioned for a different type of infraction, through one (01) resolution detailed below:

No.	Resolution	Date of finality	Sanction
01	Resolution of the Deputy Superintendency SMV No. 043-2022-SMV/11	02/06/2022	One (01) warning, for having incurred a minor infraction classified in Annex I, numeral 3, subsection 3.1 of the Sanctions Regulations.

35. That, regarding recidivism of the offender, subsection b) of Article 25 of the Sanctions Regulations establishes that the final sanction imposed by the SMV within a period of one (1) year prior to the commission of the infraction to be sanctioned is taken into account. In this regard, it has been verified that there is no recidivism on the part of the Issuer;

36. That, in relation to the circumstances of the commission of the infraction, it has been verified that the Issuer had not updated the information regarding its economic group since January 11, 2021, recording as of November 30, 2020 the concepts of total assets and equity of the companies that make up its economic group, when it should have been updated as of December 31, 2022. However, it should be noted that, as of the date of preparation of this report, the Issuer on April 8, 2024 has corrected the infraction by updating the concepts of total assets and equity as of December 31, 2022, in accordance with what was reported in the Annual Report and Annual Individual Financial Statements for fiscal year 2022;

37. That, with respect to the economic harm and its impact on the market, it has not been evidenced that the breach has produced a quantifiable harm, understood as an economic damage caused to one or several investors;

38. That, in relation to the illicit benefit resulting from the commission of the infraction, it can be stated that there are not sufficient elements to indicate that the Issuer obtained an illegal benefit as a consequence of the commission of the infraction under evaluation in the present PAS;

39. That, with respect to the probability of detection of the infraction committed, it must be pointed out that the probability is high, because this class of breaches are corroborated by the SMV itself through periodic control actions;

40. That, in relation to the existence or not of intentionality in the conduct of the offender, it can be stated that there are not sufficient elements to indicate that the Issuer acted with intent in the commission of the infractions, so this criterion would not have been met. However, it must be pointed out that although there is no evidence to indicate that the Issuer acted with intentionality, it can be affirmed that the Issuer's conduct was negligent, by not having acted with the due diligence required before obligations already known to the Issuer;

41. That, in that sense, in application of the Sanction Criteria, it is observed that the infraction committed has not caused a specific harm to the investors, the Issuer has not obtained a benefit from its illegal conduct, nor has it been proven that it acted with intent; likewise, although the Issuer has one (01) prior record, this is for a minor infraction sanctioned with a warning; additionally, that the Issuer has acknowledged the infraction and corrected the infraction

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imputed, complying with updating the information on its Economic Group on 08 April 2024 (File No. 2024015283);

42. That, taking into account the Sanction Criteria detailed previously and the evaluation carried out by this Deputy Superintendency, it is appropriate to impose on the Issuer as a sanction one (01) warning for the breach incurred, in accordance with article 35 of the Sanctions Regulation;

43. That, as previously indicated, although the Issuer stated in its defenses that it assumed its responsibility expressly and in writing for the infraction subject to charges, numeral 1 of literal a) of article 26 of the Sanctions Regulation, which establishes that upon acknowledgment of the infraction the amount to be reduced shall be fifty percent (50%) of the sanction to be imposed, would not be applicable, because the sanction to be imposed is not a fine but a warning;

44. That, the Issuer is reminded that final resolutions of sanctions imposed by the competent authorities must be reported as a material fact, within the framework of the provisions of article 5 of the Material Facts Regulation, 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 – SMV, approved by Supreme Decree No. 216-2011-EF;

RESOLVES:

Article 1.- Declare that AI Inversiones Palo Alto S.A. has incurred in one (1) infraction of a minor nature, typified in subsection 3.7 of numeral 3 of Annex I of the Sanctions Regulation, approved by SMV Resolution No. 035-2018-SMV/01, for not having updated the information on its Economic Group within the term and form established in the norm, as of the date of imputation of charges.

Article 2.- Sanction AI Inversiones Palo Alto S.A. with one (01) warning for not keeping updated the information on its Economic Group within the term and form established in the norm, as provided in article 1 of this Resolution.

Article 3.- This Resolution does not exhaust the administrative route, and it may be challenged before this Deputy Superintendency of Supervision of Market Conducts through the filing of reconsideration or appeal resources, administrative resources 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 “SMV Institutional Page on the Single Digital Platform of the Peruvian State 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 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 AI Inversiones Palo Alto S.A.

Carlos Rivero Zevallos
Deputy Superintendent
Deputy Superintendency of Supervision of Market Conducts