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Superintendency Resolution Adjunta SMV No. 054-2024-SMV/11

Lima, 22 August 2024

Summary: Sanction Compañía Minera Santa Luisa S.A. with one (1) reprimand for having incurred in one (1) infraction of a minor nature, typified in subsection 3.7 numeral 3 of Annex I of the Sanctions Regulations.

Administered : COMPAÑÍA MINERA SANTA LUISA 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. : 2024004996

The Deputy Superintendent of Supervision of Market Conducts

VIEWS:

The administrative file No. 2024004996, containing the administrative sanctioning procedure initiated by the General Intendancy of Compliance of Conducts of the Superintendency of the Stock Market – SMV (hereinafter, the IGCC), against Compañía Minera Santa Luisa S.A. (hereinafter, the Issuer); as well as Report No. 742-2024-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 knowledge of the Deputy Superintendency of Supervision of Market Conducts of the SMV (hereinafter, SASCM), the PAS of administrative file No. 2024004996 in order for it to issue decision as sanctioning body of first instance in said PAS. In this way, the SASCM assumes competence in observance in observance of the exercise of the supervision function and the sanctioning power of the Superintendency of the Stock 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 Stock 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 dictate corrective measures tending to revert the situation altered by the commission of the infraction;

II. FACTS, CHARGE, DISCHARGES 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 verification of the information about economic group published in the section of Economic Group of the Institutional Page of the SMV it was observed that the Issuer sent on 30 October 2020 the Report on its Economic Group according to the Information Formats on Economic Group (File No. 2020038989), registering as of 31 December 2019 and 30 June 2020 the concepts of total amount of assets and equity of the companies that make up its economic group;

4. That, on 31 March 2023 it sent to the SMV the report of its economic group (File No. 2023014442), in which the same data of total assets and equity reported on 30 October 2020 with relation to fiscal year 2019 was noticed, data that appear in File No. 2020038989, as can be seen below:

5. That, as of the date of imputation of charges, the total amount of assets and equity recorded in the Annual Individual Financial Statements of fiscal year 2022 presented in File No. 2023013436, were different or had varied with relation to the amount indicated in the Economic Group Report presented jointly with said financial statements; therefore, having produced a change in relation to the section “II.a Entities that make up the Economic Group” the Issuer should have updated the information about its Economic Group and not record the same data presented at the close of fiscal year 2019;

6. That, by means of Official Letter No. 1053-2024-SMV/11.2 of 04 April 2024 (hereinafter, Charge Letter), the IGCC imputed to the Issuer the commission of the infraction typified in subsection 3.7 of numeral 3 of Annex I of the Sanctions Regulations, which provides that it constitutes minor infraction: “Not presenting to the SMV or, when applicable, to the entity responsible for a centralized negotiation mechanism, or not keeping updated, the information about its Economic Group, as well as not informing the SMV, the 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 Stock Market, within the term or form established in the regulations of the matter.” (Underline added);

2.3 Discharges and allegations

7. That, the Issuer did not submit its defense despite having been duly notified with the Letter of Charges, via the MVNet System, on 04 April 2024, in accordance with article 261 of the Regulation of the MVNet System and SMV Virtual, approved by Superintendente Resolution No. 092-2020-SMV/02, in force at the time of notification (hereinafter, MVNet Regulation)2 ;

8. That, the TUO of the LPAG 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 indicates 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 severity of the damage to the public interest and/or protected legal right, (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;

9. That, the charge formulated and the criteria regarding the graduation of the sanction have been subject to evaluation in the Report, which has been brought to the attention of the SASCM;

10. That, in observance of the provisions of numeral 5

[1] Article 26.- Moment and effectiveness of Notifications Notifications to obligated entities produce legal effects when they are deposited in the electronic domicile of the obligated entity. The term for the exercise of actions by the administered is counted from the business day following the deposit in the electronic domicile. The means to prove the receipt of information by the obligated entities will be given by the respective records contained in the MVNET log, which will be available to the obligated entities when they require it." (Underline added).

[2] It should be noted that as of 20 March 2024, the new Regulation of the MVNet System and SMV Virtual, approved by SMV Resolution No. 004-2024-SMV/01, is in force, except for the articles on electronic notifications, which entered into force on 30 April 2024.

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of article 255 of the TUO of the LPAG, through Letter No. 3248-2024-SMV/11 of 25 July 2024, the Report was sent to the Issuer so that it may formulate its arguments within the term of five (05) business days of notification;

11. That, on 05 August 2024, the Issuer submitted its arguments, which are detailed below summarily:

(i) Acknowledgment of the imputed infraction

The Issuer states that only upon notification of the Letter of Charges did it notice the error incurred in the information of its economic group, "(...) by recording incorrect information in the report submitted on 31 March 2023, regarding the total assets and liabilities corresponding to fiscal year 2022."

In that sense, the Issuer expressly, precisely, concisely, clearly and unconditionally acknowledges having incurred the infraction imputed in the Letter of Charges. It also indicates that, in accordance with the provisions of article 26 of the Sanctions Regulation, if a fine sanction is applied, it must be reduced by 30%.

(ii) On the voluntary correction of the imputed infraction

The Issuer states "In addition to the acknowledgment made, (...) we have complied with updating the information regarding the amounts of assets and equity (...)."

In that sense, the Issuer requests that the correction made be taken into consideration as a mitigating factor of responsibility, in accordance with the provisions of article 26 of the Sanctions Regulation.

(iii) On the proportionality of the proposed fine and the evaluation of the sanction criteria

In its arguments, the Issuer states that it agrees with what is indicated in the report regarding that it has no record of sanctions, does not qualify as recidivist, no economic harm has occurred nor is there any repercussion in the market, no illicit benefit was obtained, the probability of detection is high, there is no severity of damage to the public interest, that there is no intent in the commission of the infraction; while, regarding the circumstances of commission of the infraction, it requests that the mitigating factors of responsibility for acknowledgment of responsibility and correction be taken into consideration.

Accordingly, the Issuer argues: "(...) the sanction criteria reflect (i) the low impact of the Imputed Infraction, (ii) the lack of aggravating factors on the part of Santa Luisa, and (ii) the existence of mitigating factors that imply a reduction of the possible sanction to be imposed. This being so, the fine proposed by the IGCC does not correspond to what is strictly necessary for the protection of public purposes, for which we consider that there is not sufficient basis for the imposition of a fine equivalent to 5UIT." Consequently, it requests that a warning sanction be imposed for the non-compliance detailed in the Letter of Charges.

III. ISSUES TO BE DETERMINED

12. That, in the present PAS it corresponds to determine the following:

(i) Whether or not the Issuer incurred the infraction indicated in the Letter of Charges and Report.

(ii) Whether or not it corresponds to impose a sanction on the Issuer.

IV. ANALYSIS

4.1 Applicable regulations

13. That, Article 13 of the TUO of the LMV establishes that: “(…) Legal entities registered in the Registry and the issuer of registered securities are obligated to submit the information that this law and other general provisions establish, being responsible for the veracity of said information.”;

14. That, Article 7 of the Regulation on Indirect Ownership, Linkage and Economic Groups, approved by SMV Resolution No. 019-2015-SMV-01 and amendments (hereinafter, the Economic Group Regulation), establishes the definition of Economic Group: “Article 7.- DEFINITION OF ECONOMIC GROUP Economic Group is the set of entities, national or foreign, made up of at least two entities, when one of them exercises control over the other or others or when control over the entities corresponds to one or several natural persons acting as a decision unit. Natural persons do not form part of the economic group.”;

15. That, in relation to the obligation to submit information on the Economic Group, Article 8 of the Economic Group Regulation provides: “Issuers of securities registered in the Registry, legal entities registered therein, and the EAFC are obligated to submit to the SMV and, when applicable, to the entity responsible for a centralized trading mechanism in which said securities are registered, the reports on their Economic Group, in accordance with the formats established by the SMV. (Underline added);

16. That, regarding the timing of the submission of information, the second paragraph of Article 9 of the Economic Group Regulation establishes3: “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 subject, unless the change qualifies as a material fact or relevant fact, in which case, without prejudice to the respective communication, the obligated subject must update said information within the following fifteen (15) calendar days. Said update must be made in accordance with the formats indicated in the first paragraph of the preceding article and, when applicable, must also be sent to the entity responsible for the mechanism

[3] Second paragraph of Article 9 of the Economic Groups Regulation amended by Article 6 of SMV Resolution No. 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 following year of occurrence, unless the change qualifies as a material fact or relevant fact, in which case, without prejudice to the respective communication as such, the obligated subject must update said information within the following fifteen (15) calendar days. Said update must be made in accordance with the formats indicated in the first paragraph of the preceding article and, when applicable, must also be sent to the entity responsible for the centralized trading mechanism in which the securities are registered.” (Underline added).

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centralized trading mechanism in which the securities are registered.” (Underline added);

17. That, in relation to the form of presentation of the Economic Group information, the provisions of Articles 8 and 9 above are 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 Securities Market.”;

18. That, in that sense, the obligated entities must comply with the update 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 of 15 June 2016;

19. That, in this regard, section “II.a Entities that make up the Economic Group” of the Economic Group Information Formats contains numeral “vii. Total value of assets and equity: Indicate amount and currency” and it is stated “Note (1) The data of Total Assets and Equity shall refer to the fiscal year immediately preceding the date of submission of the Economic Groups information”, therefore this information may be updated periodically each year with data of total assets and equity as of the fiscal year immediately preceding the date of submission;

4.2 Evaluation of the case

20. That, in file No. 2024004996 containing the documentation of this PAS, it is noted that through Memorandum No. 1974-2022-SMV/11.1 of 13 May 2022 (File No. 2022020977) and Memorandum No. 3043-2023-SMV/11.1 of 24 July 2023 (File No. 2023031683), the General Superintendence of Conduct Supervision (hereinafter, IGSC) —an organ of the Superintendence of the Securities Market – SMV which has among its functions and powers the supervision of compliance with the rules applicable to issuers with securities registered in the RPMV—, sent to the IGCC the result of its evaluation, and specifically what refers to the present case;

21. 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 concludes it with a report of indications of infringement, determine that its pronouncement 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 said opinion and the IGSC's report of indications of infringement are not binding on the IGCC, as established in

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the second paragraph of article 9 of the Sanctions Regulations4 5;

22. That, in this way, it is established that in the evaluation of the facts related to the present PAS, two (2) other bodies of the Superintendency of the Stock 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 evaluation, formulated the Charge Report and the Report; and at this point of the PAS, it falls to the Office of the SASCM to issue a pronouncement containing its decision regarding the aforementioned charge, it being necessary to indicate that due to its nature, it will be a first-instance administrative decision;

23. That, as a preliminary matter, it must be pointed out that the Issuer has not submitted its defense regarding the charges formulated against it in this proceeding;

24. That, by means of a brief of arguments submitted on 05 August 2024, within the period granted to formulate objections to the investigation report, the Issuer acknowledged responsibility for the infringement subject to the charge. It must be specified that, in accordance with item 2 of subsection a) of article 26 of the Sanctions Regulations, in the event that a fine sanction is determined, it must be reduced by 30%;

25. That, likewise, by means of the brief of arguments, the Issuer requested that the voluntary remediation of the non-compliance be taken into account as a mitigating factor of responsibility for the infringement subject to the charge. It must be specified that the mitigating condition of responsibility indicated will be evaluated and, where appropriate, considered at the time of the Determination of the Sanction;

26. That, the sanctioning criteria developed by the Issuer in its brief of arguments will be evaluated at the time of the Determination of the Sanction;

27. That, in the present case, it has been verified that the

[4] Article 245 of the TUO of the LPAG indicates as forms or ways in which the oversight activity could be concluded the following: 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 to initiate a procedure in order to determine the administrative responsibilities that may correspond; 5) The adoption of corrective measures and 6) Other forms as established by special laws.

[5] Article 9.- PRELIMINARY INQUIRIES AS A CONSEQUENCE OF SUPERVISION ACTIONS (…) When such bodies conclude that there are sufficient indications of possible administrative infringements, they forward the corresponding reports to the General Compliance Directorates, which determine whether or not it is appropriate to initiate an administrative sanctioning procedure. Where appropriate, the General Compliance Directorates may carry out additional inspections or investigations of the reported indications. In the case of possible infringements within the scope of the Regulations on the Activity of Participatory Financial Financing and its Managing Companies, the preliminary inquiries are carried out by the General Directorate of Research and Innovation, which, if there are sufficient indications of possible administrative infringements, will determine whether or not it is appropriate to initiate an administrative sanctioning procedure. (…).

The Issuer did not submit its Economic Group Report until 31 March 2021 (deadline) with respect to the 2020 fiscal year. Likewise, it is noted that the Economic Group Report submitted on 09 May 2022 (File No. 2022020236) and on 31 March 2023 (File No. 2023014442) contain the same total asset and equity amounts as of 31 December 2019 and 30 June 2020, presented in the Economic Group Report on 30 October 2020 (File No. 2020038989). However, this last report submitted on 31 March 2023 should have been updated as of 31 December 2022;

28. That, as of the date of the charges, with respect to the aforementioned last report submitted on 31 March 2023, the total asset and equity amounts stated in the Annual Individual Financial Statements for the 2022 fiscal year submitted in File No. 2023013436 were different or had varied in relation to the amount indicated in the Economic Group Report submitted together with said financial statements; therefore, given that a change occurred in relation to section “II.a Entities comprising the Economic Group”, the Issuer should have updated the information on its Economic Group and not stated the same amounts presented at the close of the 2019 fiscal year and 30 June 2020;

29. That, likewise, it should be noted that on 21 June 2024 the Issuer submitted the Report on its Economic Group (File No. 2024027076), from which it is observed that the total asset and equity amounts stated are identical to the data presented in the Annual Individual Financial Statements for the 2022 fiscal year; however, the Issuer stated 31 December 2023 as the date of the total asset and equity amount in the aforementioned report;

30. That, without prejudice to the foregoing, it should be noted that, in accordance with what is stated in its pleadings, to date, the Issuer has complied with submitting the Report on its Economic Group (File No. 2024033852) on 05 August 2024, from which it is observed that the total asset and equity amounts have been updated as of 31 December 2023;

31. That, consequently, having proven the conduct constituting an infraction and determined the administrative liability of the Issuer, it is appropriate to analyze the proposed sanction in accordance with the principle of reasonableness and the sanction criteria, considering that the Issuer, through a written pleading, acknowledged liability for the infraction and, in addition, has remedied the non-compliance to date;

V. DETERMINATION OF THE SANCTION

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

“Not submitting to the SMV or, where applicable, to the entity responsible for a centralized trading mechanism, or not keeping updated, the information on its Economic Group, as well as not reporting to the SMV the share transfers that imply a change in the decision-making or control unit, or any modification of the data contained in the Public Registry of the Securities Market, within the period or in the form established in the regulations on the matter.” (Underlining added);

33. That, in accordance with article 35 of the Sanctions Regulations, said infraction is sanctionable with a reprimand or a fine of not less than one

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(01) UIT and up to twenty-five (25) UIT;

34. 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 Regulation, which develop the criteria for grading the sanction, these being: (i) the issuer's sanction history, (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 conduct of the offender (hereinafter, Sanction Criteria);

35. That, with respect to the severity of the harm to the public interest and/or protected legal interest, it is relevant to note that with respect 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 the 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 a severity of harm to the public interest is not evident, the non-compliance with the obligation to inform the market within the deadlines on the part of the issuers affects the transparency of the market, which is considered a protected legal interest;

36. That, with respect to the sanction history, literal a) of article 25 of the Sanctions Regulation establishes that these are 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 (in this case, March 31, 2021); notwithstanding this, it is specified that the commission of the same infraction in the year prior to the infraction to be sanctioned is not considered as a history. In this regard, from the verification carried out in the SMV Sanctions System, it has been determined that the Issuer the Issuer does not have a sanction history

37. That, regarding the recidivism of the offender, literal b) of article 25 of the Sanctions Regulation establishes that the final sanction imposed by the SMV within the 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;

38. That, in relation to the circumstances of the commission of the infraction, it has been verified that the Issuer did not submit its Economic Group Report until March 31, 2021 (deadline) with respect to fiscal year 2020. Likewise, it is observed that the Economic Group Report submitted on May 9, 2022 (File No. 2022020236) and on March 31, 2023 (File No. 2023014442), contain the same amounts of total assets and equity as of December 31, 2019 and June 30, 2020, submitted in the Economic Group Report on October 30, 2020 (File No. 2020038989). Likewise, the report submitted on March 31, 2023 should have been updated as of December 31, 2022. Notwithstanding this, it should be noted that, as indicated in its arguments, to date, the Issuer has complied with submitting the Report on its Economic Group (File No. 2024033852) on August 5, 2024, from which it is observed that the total amount of assets and equity have been updated as of December 31, 2023, as seen at

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below:

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

40. 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;

41. That, with respect to the probability of detection of the infraction committed, it must be noted that the probability is high, because this class of non-compliances are corroborated by the SMV itself through periodic control actions;

42. That, in relation to the severity of the harm to the public interest and/or protected legal interest, it is relevant to note that in relation to the severity of the harm to the public interest and/or protected legal interest, it must be indicated that the timely submission of the Economic Group Report by the 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 a severity of harm to the public interest is not evidenced, the non-compliance with the obligation to inform the market within the deadlines on the part of the issuers affects the transparency of the market, which is considered a protected legal interest;

43. That, in relation to the existence or not of intentionality in the conduct of the offender, it can be noted 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 configured. However, it is necessary to indicate that although there is no evidence to indicate that the Issuer acted with intentionality, it can be affirmed that the conduct of the Issuer was negligent, by not having acted with the required diligence before obligations already known by the Issuer;

44. That, in this sense, in application of the Sanction Criteria, it is observed that the infraction committed has not caused a concrete 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 and it also does not have a sanction history; likewise, it is necessary to take into consideration that the Issuer acknowledged responsibility for the infraction subject to imputation and, to date, has also remedied the non-compliance, situations that are considered as mitigating factors of responsibility for infractions;

45. That, in this sense, in application of the Sanction Criteria, it is observed that the infraction committed has not caused a concrete 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, it does not have a history nor is it a recidivist; likewise, attending to the mitigating factors of responsibility for acknowledgment of responsibility and remediation indicated in article 26 of the Sanctions Regulation, this Deputy Superintendency considers imposing as a sanction one (1) warning for the non-compliance incurred, in accordance with article 35 of the Sanctions Regulation;

In accordance with the provisions of numerals 13 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 Compañía Minera Santa Luisa S.A. has incurred one (1) minor infraction, classified under subsection 3.7 of numeral 3 of Annex I of the Sanctions Regulation, approved by SMV Resolution No. 035-2018-SMV/01, for failing to update the information regarding its Economic Group within the term and in the manner established in the regulation, as of the date of the imputation of charges.

Article 2.- Sanction Compañía Minera Santa Luisa S.A. with one (1) warning for failing to keep the information regarding its Economic Group updated within the term and in the manner established in the regulation, pursuant to 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 Market Conduct Supervision by filing motions for reconsideration or appeal, administrative remedies 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.- If this Resolution is not challenged, it must be published on the "SMV Institutional Page on the Single Digital Platform of the Peruvian State for Citizen Guidance (www.gob.pe/smv)", in observance of the provisions of numeral 1 of Article 7 of the "Policy on the 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 pursuant to the provisions of the last paragraph of Article 14 of the Sanctions Regulation, approved by SMV Resolution No. 035-2018-SMV/01.

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Article 5.- Transcribe this Resolution to Compañía Minera Santa Luisa S.A.

Signed by: RIVERO ZEVALLOS Carlos Fabian FAU 2013 Reason:

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

Signed by: MENESES CAMARGO Carlos Er
Reason: