Superintendent Resolution No. 077-2025-SMV/02

PERÚ Ministry of Economy and Finance

SMV
Securities Market
Superintendence
Electronically signed document within the framework of Law No. 27269, Law of Digital Signatures and Certificates, its regulations and amendments. The integrity of the document and authorship Superintendent Resolution No. 077-2025-SMV/02 Lima, July 4, 2025 The Superintendent of the Securities Market SEEN:
The File No. 2025023227 and Report No. 906-2025- SMV/10.2 of July 4, 2025, issued by the General Superintendence of Entity Supervision, with the favorable ruling of the Deputy Superintendent of Prudential Supervision; CONSIDERING:
That, by Resolution CONASEV No. 012-2008-
EF/94.01.1 of February 27, 2008, operating authorization was granted to NCF Sociedad Administradora de Fondos de Inversión S.A. 1 to administer only investment funds, now Diviso Fondos Sociedad Administradora de Fondos S.A. (hereinafter, DIVISO SAF). Subsequently, by Resolution CONASEV No. 054-2011- EF/94.01.1 of June 30, 2011, the Securities Market Superintendence -SMV authorized DIVISO SAF to additionally administer mutual investment funds in securities; That, by means of Letter No. 719-2025-SMV/10.2 2 (hereinafter, LETTER 719) of February 6, 2025, the General Superintendence of Entity Supervision (hereinafter, IGSE) communicated to DIVISO SAF that Diviso Grupo Financiero S.A. (hereinafter, DGF) and Andean Equity Financial Ltd (hereinafter, ANDEAN EQUITY) would cease to have recognized economic solvency, in accordance with the provisions of articles 4 and 11-A of the Common Rules for entities requiring authorization of organization and operation of the SMV, approved by SMV Resolution No. 039-2016-SMV/01 and its amendments (hereinafter, COMMON RULES), and they were required to present documentation accrediting the remediation of the observed situation; That, DIVISO SAF responded to LETTER 719 (hereinafter, SHAREHOLDERS' RESPONSE) with letters and attachments dated February 11, 2025 (hereinafter, LETTERS), in which DGF and ANDEAN EQUITY explain the actions they plan to execute as part of their so-called "Patrimonial Strengthening Plan" (hereinafter, STRENGTHENING PLAN); That, with Letter No. 1157-2025-SMV/10.2 of February 26 2025; the Deputy Superintendence of Prudential Supervision (hereinafter, SASP) communicated to DIVISO SAF that, according to the SHAREHOLDERS' RESPONSE, the observations regarding DGF and ANDEAN EQUITY had not yet been remedied, and they were required that, within a period not exceeding thirty (30) calendar days, they

1 By Universal Shareholders' Meeting held on November 29, 2013, it was agreed to approve the modification of the company name to Diviso Fondos Sociedad Administradora de Fondos S.A.
2 File No. 2025005119.

PERÚ Ministry of Economy and Finance

SMV
Securities Market
Superintendence
Electronically signed document within the framework of Law No. 27269, Law of Digital Signatures and Certificates, its regulations and amendments. The integrity of the document and authorship reverse the non-compliance situation referred to in LETTER 719 regarding the economic solvency of the aforementioned shareholders and accredit, with the respective documentary support, that said situation was not maintained; That, DIVISO SAF, by writing of March 26, 2025, requested an extension of one hundred eighty (180) calendar days for the remediation of the observations referred to DGF and ANDEAN EQUITY having ceased to have recognized economic solvency; That, by Letter No. 1832-2025-SMV/10.2 the SASP granted to DIVISO SAF an extension of 30 calendar days, which expired on April 30
2025. Therefore, by that date it was necessary to accredit, with the respective support
documentary, that DGF and ANDEAN EQUITY had economic solvency, in accordance with the applicable regulations; That, for its part, the IGSE with Letter No. 1794-2025- SMV/10.2 of March 28, 2025, required DIVISO SAF information 3 with the purpose of evaluating the impact that the events described in the STRENGTHENING PLAN would have, which, as indicated in the LETTERS, would allow recovering the economic solvency of DGF and ANDEAN EQUITY; That, however, DIVISO SAF, by means of relevant fact 4 dated April 29, 2025, informed about the transfer of all shares representative of its share capital to eleven (11) new shareholders: Yésica Ysabel Del Carpio, Nicole Alexandra Espinoza Rengifo, Evely Herrera Peña, José Augusto Domenack Casas, Julio Angel Peraltilla Fernandez Baca, Diego Jesús Rodríguez Torres, Miguel Ángel Rodríguez Vargas, Enma Dabida Rojas Pomahuali, Julio César Kanashiro Tome, Catalina Rabinovich Woloshin and Janina Rosalinda Castro Nuñez; That, DIVISO SAF informed, by relevant fact 5 on May 7 2025, that Mr. José Augusto Domenack Casas transferred all the shares representative of the share capital of his ownership in favor of Mrs. Esperanza Teresa Livelli Bacigalupo; That, by Letter No. 3009-2025-SMV/10.2 (hereinafter, LETTER 3009) 6 of May 26, 2025, it was required of DIVISO SAF to send, among others, the sworn declaration of patrimonial assets of the following shareholders: Yésica Ysabel Del Carpio, Nicole Alexandra Espinoza Rengifo, Evely Herrera Peña, Esperanza Teresa Livelli Bacigalupo, Julio Angel Peraltilla Fernandez Baca, Diego Jesús Rodríguez Torres, Miguel Ángel Rodríguez Vargas, Enma Dabida Rojas Pomahuali, Julio César Kanashiro Tome, Catalina Rabinovich Woloshin and Janina Rosalinda Castro Nuñez (hereinafter, SHAREHOLDERS), indicating if they are subject to any type of encumbrance or limitation for their free availability, as well as a list of their debts;

3 It was requested, among others: i) the statement of financial position, statement of results and notes to the financial statements of ANDEAN EQUITY and Esquema Investment S.A., ii) copy of the contract signed on February 13, 2025 between Caja Rural de Ahorro y Crédito Los Andes S.A. and DGF, for the sale of the latter's participation in the Alternative Credit Company S.A. and iii) copy of the purchase and sale contract of 99.99% of shares of Esquema Investment S.A., celebrated between DGF and Bleauvelt Enterprises S.A. 4 File No. 2025019334. 5 File No. 2025021057. 6 File No. 2025023227.

PERÚ Ministry of Economy and Finance

SMV
Securities Market
Superintendence
Electronically signed document within the framework of Law No. 27269, Law of Digital Signatures and Certificates, its regulations and amendments. The integrity of the document and authorship That, DIVISO SAF responded to LETTER 3009 by means of writings of June 04 and 05, 2025, attaching the sworn declarations of patrimonial assets (hereinafter, PATRIMONIAL DECLARATION) of the SHAREHOLDERS; That, by means of Letter No. 3347-2025-SMV/10.2 (hereinafter, LETTER 3347) of June 16, 2025, it was required complementary information to DIVISO SAF regarding Mr. Julio César Kanashiro Tome, Catalina Rabinovich Woloshin and Janina Rosalinda Castro Nuñez; That, DIVISO SAF requested, by letter on June 24, 2025, an extension of ten (10) business days to respond to the request made through LETTER 3347; That, with Letter No. 3464-2025-SMV/10.2 of June 24, 2025, an extension of ten (10) business days was granted to DIVISO SAF regarding LETTER 3447, which will expire on July 7, 2025; That, to determine if it corresponds to suspend the operating authorization of DIVISO SAF it is necessary to analyze, previously, the competence of the Superintendent of the Securities Market (hereinafter, SMV) to issue such a measure and the circumstances that must be considered for the exercise of this faculty; That, in accordance with what is established in article 3, numeral 14, literal ii), of the Concordant Single Text of the Organic Law of the Superintendence of the Securities Market, approved by Decree Law No. 26126 and its amendments, the Superintendent of the Securities Market is empowered to suspend automatically the operating authorization granted to legal entities under its supervision and control, without it being necessary to initiate an administrative sanctioning procedure, among other cases, when any of its shareholders incurs in impediment or ceases to comply with the requirements established by the regulation. Likewise, in case of subsisting the non-compliance that originates the suspension, the Superintendent of the Securities Market may revoke the operating authorization without it being necessary to initiate an administrative sanctioning procedure; That, in accordance with article 11-A of the COMMON RULES all shareholders of entities 7 , such as mutual investment fund and investment fund management companies and stock exchange agent companies must have, at all times, to the satisfaction of the SMV, economic solvency; That, when any of the shareholders loses or ceases to comply with one of the conditions and/or requirements to be a shareholder, he or the entity must inform said situation to the SMV immediately after having taken knowledge of said circumstance and proceed, if applicable, to its immediate remediation. This, in accordance with article 30-A of the Regulation of Intermediation Agents, approved by Superintendent Resolution No. 034-2015-SMV/01 and its modifying norms (hereinafter, AI REGULATION). Likewise, when the SMV takes knowledge of the fact, the
Deputy Superintendence of Prudential Supervision, or the body that acts in its place, may grant a period to the supervised company to reverse the non-compliance situation or accredit that the situation that generated the non-compliance of the conditions and/or requirements that its shareholders must comply with permanently, which may be extended only once in attention to duly justified reasons;

7 Article 2 of the COMMON RULES defines Entities as legal persons that require authorization of organization of the SMV and that are included in article 1 of the present norm. In that sense, the
article 1 of the COMMON RULES, includes within its scope of application mutual investment fund management companies, investment fund management companies and stock exchange agent companies.

PERÚ Ministry of Economy and Finance

SMV
Securities Market
Superintendence
Electronically signed document within the framework of Law No. 27269, Law of Digital Signatures and Certificates, its regulations and amendments. The integrity of the document and authorship situation that generated the non-compliance of the conditions and/or requirements that its shareholders must comply with permanently, which may be extended only once in attention to duly justified reasons; That, if a period has been granted, and upon its expiration, the non-compliance of the conditions and/or requirements that must be complied with permanently by the shareholders of a fund management company and stock exchange agent company persists, the Superintendent of the Securities Market may suspend the operating authorization of the aforementioned entities and, if the non-compliance persists, may revoke said authorization; From the financial situation of DIVISO SAF That, according to the financial information sent by DIVISO SAF, it has been taken knowledge that at the close of the 2024 exercise 8 , it registered negative results of S/ 4,201 thousand. These results are explained mainly by the devaluation of the investments that this entity made in investment fund quotas and by the increase in its administrative expenses; That, upon analyzing the results included between the exercises 2020 to 2024, it was found that DIVISO SAF reports accumulated losses of S/ 7,890 thousand; Chart No. 1 Source: Results statements sent by DIVISO SAF (*) 2025 information corresponds to accumulated results at the close of March for DIVISO SAF 9 . That, additionally, it is known that, as result of the external audit of DIVISO SAF, corresponding to the 2024 exercise, the audit opinion prepared by Gaveglio Aparicio y Asociados Sociedad Civil de Responsabilidad Limitada was issued, in which a qualified opinion was expressed due to the inability to obtain evidence of the value of the real estate assets in which an investment fund in which DGF is a participant invests; it should be specified that DIVISO SAF owns 13.58% of the shares representative of the share capital of DGF. The qualified audit opinion would result in adjustments in the valuation of DIVISO SAF's assets; That, the historical economic results evidence a deficient management in the entity. This situation seriously compromises the financial position of DIVISO SAF and makes highly probable the need to make future capital contributions by the shareholders, in order to comply with the minimum patrimonial levels required by the current regulation on prudential limits; From the shareholding composition of DIVISO SAF That, DIVISO SAF communicated the new composition of its shareholding, according to the detail of the following table:
Table No. 1
Shareholder participation in the share capital of DIVISO SAF No. LAST NAMES AND NAMES SHARE PARTICIPATION 1 CASTRO NUÑEZ, JANINA ROSALINDA 9% DEL CARPIO CASTRO, YÉSICA YSABEL (hereinafter, YÉSICA DEL CARPIO) 10% ESPINOZA RENGIFO, NICOLE ALEXANDRA (hereinafter, NICOLE ESPINOZA) 8% HERRERA PEÑA, EVELY (hereinafter, EVELY HERRERA) 8% 5 KANASHIRO TOMÉ, JULIO CÉSAR 10% LIVELLI BACIGALUPO, ESPERANZA TERESA (hereinafter, ESPERANZA LIVELLI) 10% PERALTILLA FERNANDEZ BACA, JULIO ÁNGEL (hereinafter, JULIO PERALTILLA) 10% 8 RABINOVICH WOLOSHIN, CATALINA 10% RODRÍGUEZ TORRES, DIEGO JESÚS (hereinafter, DIEGO RODRÍGUEZ) 8% 10 RODRÍGUEZ VARGAS, MIGUEL ÁNGEL (hereinafter, MIGUEL RODRÍGUEZ) 9% 11 ROJAS POMAHUALI, ENMA DABIDA (hereinafter, ENMA ROJAS) 8% From the analysis of the economic solvency of the shareholders of DIVISO SAF
1) GENERAL CRITERIA

PERÚ Ministry of Economy and Finance

SMV
Securities Market
Superintendence
Electronically signed document within the framework of Law No. 27269, Law of Digital Signatures and Certificates, its regulations and amendments. The integrity of the document and authorship That, the IGSE evaluated the economic solvency of the following shareholders of DIVISO SAF: YÉSICA DEL CARPIO, NICOLE ESPINOZA, EVELY HERRERA, ESPERANZA LIVELLI, JULIO PERALTILLA, DIEGO RODRÍGUEZ, MIGUEL RODRÍGUEZ and ENMA ROJAS (hereinafter and collectively, EVALUATED SHAREHOLDERS). For this, it reviewed the information presented by DIVISO SAF in response to LETTER 3009, as well as the information obtained by the SMV within the framework of its supervisory functions; That, in the evaluation that the IGSE performs on the economic solvency of the organizers and shareholders, it considers their patrimonial backing and their capacity to be able to carry out successive capital increases that allow the entity to face significant operational costs during the development of its operations. For this purpose, special attention must be paid to the liquid assets, or eventually to the easily liquidable assets, with which the organizers or shareholders have; That, in the present case, the IGSE evaluated the economic solvency of the aforementioned shareholders considering the payment they must make for the shares of DIVISO SAF, without including the interests. Likewise, its economic solvency was analyzed based on the minimum required capital 10 to a fund management company. In this way, consistently, the prudential requirement applied to a fund management company is transferred to its shareholders, who are the last responsible for its patrimonial backing, taking into account that, according to the COMMON RULES, the requirements of economic solvency and moral suitability are applicable to shareholders by virtue of their condition as such; That, it should be noted that the analysis of the moral suitability of the EVALUATED SHAREHOLDERS has not been carried out;
2) CONDITIONS OF THE SHARE PURCHASE SALE
That, prior to the patrimonial analysis, the conditions of the share purchase sale by the SHAREHOLDERS must be highlighted. For what following, some aspects of the purchase and sale contracts (hereinafter, CONTRACTS):

• The sale price will be paid by the SHAREHOLDERS in eight (8) installments,
  during the term of eight (8) years and three (3) months as follows:
• Table No. 2
• Payment schedule for the purchase of DIVISO SAF shares according to the percentage acquired by each SHAREHOLDER 11
• (Amounts expressed in soles)
  PAYMENT PAYMENT DATE
  PAYMENTS PER SHAREHOLDER
  8% Participation
  9% Participation
  10% Participation
  Payment 1 26/07/2026 123,228.55 138,632.12 154,035.69 Payment 2 26/07/2027 55,378.84 62,301.19 69,223.55

10 By Circular No. 011-2025-SMV/10.2 of January 6, 2025, it was communicated to DIVISO SAF that the minimum capital for the year 2025 for fund management companies was S/ 1,804,746.00.
11 The amounts described in Table No. 2 were calculated based on the payment schedule detailed as an annex in each of the CONTRACTS. In that sense, these amounts include the principal plus the interest on the debt.

PERÚ Ministry of Economy and Finance

SMV
Securities Market
Superintendence
Electronically signed document within the framework of Law No. 27269, Law of Digital Signatures and Certificates, its regulations and amendments. The integrity of the document and authorship PAYMENT PAYMENT DATE PAYMENTS PER SHAREHOLDER 8% Participation 9% Participation 10% Participation Payment 3 26/07/2028 55,534.51 62,476.33 69,418.14 Payment 4 26/07/2029 55,378.84 62,301.19 69,223.55 Payment 5 26/07/2030 55,378.84 62,301.19 69,223.55 Payment 6 26/07/2031 55,378.84 62,301.19 69,223.55 Payment 7 26/07/2032 55,534.51 62,476.33 69,418.14 Payment 8 26/07/2033 1,103,378.84 1,241,301.19 1,379,223.55 TOTAL 1,559,191.77 1,754,090.73 1,948,989.72 It should be noted that the price per share of DIVISO SAF is S/ 1.00. Likewise, according to the CONTRACTS, the payment schedule contemplates a financing cost corresponding to an effective annual rate of 5.21%. Regarding the SHAREHOLDERS; the total payment for the shares of DIVISO SAF is S/ 13,837,826.97. This amount considers the financing costs.

• The payment of the shares will be made only with the funds received
  by way of dividends. In case the dividends are not sufficient for the payment of the installment, the unpaid balance will accumulate to the installment of the following year, and so on, until the maturity date of the last installment provided in the payment schedule. In no case will the SHAREHOLDERS pay with resources other than the dividends of DIVISO SAF.
• If upon reaching the last installment, the dividends received by the SHAREHOLDERS
  prove insufficient to cover the pending balance of payment of the installments of the purchase-sale; the contract will be resolved ipso jure, without judicial declaration in accordance with the provisions of articles 1371 and 1430 of the Civil Code. In this case, the sellers waive the forced execution of the contract and of any debt, whereby the SHAREHOLDERS are released.
• The shareholders may unilaterally resolve the contract, in accordance
  with article 1430 of the Civil Code, in case they take knowledge of the existence or the start of any process or judicial action, administrative, laboral, arbitral, concursal or any other type of process that falls directly or indirectly on the shares subject to sale.
• In the two preceding cases, the shares will return to the ownership of the
  SELLERS who will retain for themselves as the sole and exclusive penalty or responsibility in their favor all payments made by way of sale price until the resolution of the contract.
  That, in accordance with the foregoing, it is known that, if the payment must be made with the distribution of dividends, it is necessary to analyze the data of the net profits and the dividend distributions made during the last years:

PERÚ Ministry of Economy and Finance

SMV
Superintendencia del Mercado de Valores
Document electronically signed digitally under the framework of Law No. 27269, Law of Digital Signatures and Certificates, its Regulations and amendments. The integrity of the document and authorship

Table No. 3
Historical profits and dividends 2020 – 2024 of DIVISO SAF (Amounts expressed in thousands of soles)

FISCAL YEAR
DIVISO SAF
Profit (loss)
Dividend distribution
2020 S/ 675.00 NO
2021 (S/ 3,903.00) NO
2022 (S/ 1,353.00) NO
2023 S/ 892.00 NO
2024 (S/ 4,201.00) NO
TOTAL (S/ 7,890.00) -

That, as stipulated in the CONTRACTS, although the SHAREHOLDERS are not obligated to cover the payment of the installments with their own resources, according to subsection 2.5 of said contracts it is established that "(...) In no case shall the Shareholder of the Company pay with resources other than the dividends of the Company, the Annual Installments";

That, without prejudice to the implications that the aforementioned clause limits shareholders to canceling, if they so wish, the amount of the installments with their own resources, it must be indicated that, during the last five (5) years, that is between the years 2020 and 2024, no dividends were distributed. Likewise, it can be evidenced that the accumulated net profits during said period have been negative, in this way DIVISO SAF registers accumulated losses of S/ 2,411.49 thousand and S/ 7,890.00 thousand, respectively;

That, it must be highlighted that, although historical results do not necessarily repeat in the future, it is the duty of the SMV to make decisions prudently in protection of the integrity of the market. Considering this, and taking into account the results recorded in the last five (5) years, there are no elements that support the probability that the EVALUATED SHAREHOLDERS can pay for the shares purchased of DIVISO SAF for an amount of S/ 9,301,000.00 (without considering the financing cost that is included in the CONTRACTS) 12;

That, in this scenario, if these amounts cannot be paid, upon maturity of the last installment, the SHAREHOLDERS lose what was paid and the sellers become owners of the shares again;

That, the clauses of the CONTRACTS under which the sellers can recover ownership of the shares (second clause, subsections 2.6, 2.7 and 2.8) imply a legal act that involves directly the ownership of more than ten percent (10%) of the shares representing the social capital, and that grants to a third party the exercise of voting rights in said percentage, of DIVISO SAF;

That, on this point, according to article 12 of the COMMON RULES, every legal act that involves directly more than ten percent (10%) of the shares representing the social capital and that grants to a

12 This, without considering the cost that the OTHER SHAREHOLDERS would have to pay with the dividends of DIVISO SAF.

PERU Ministry of Economy and Finance

SMV
Superintendencia del Mercado de Valores
Document electronically signed digitally under the framework of Law No. 27269, Law of Digital Signatures and Certificates, its Regulations and amendments. The integrity of the document and authorship third party the exercise of voting rights in said percentage must have the prior authorization of the SMV;

That, in this order of ideas, although the CONTRACTS have been presented through which the sellers would transfer ownership of the shares to the SHAREHOLDERS, there is also a legal act 13 (in accordance with article 140 of the Civil Code) through which a transfer is established from the SHAREHOLDERS to the sellers subject to the suspensive condition established in the second clause, subsections 2.6, 2.7 and 2.8, of the CONTRACTS. This, in the following scenarios:

• If upon the payment date of the last installment of the schedule, the dividends received by the SHAREHOLDERS prove insufficient to cover the outstanding balance of the sale price, the shares will return to full ownership of the SELLERS. It must be remembered that the SHAREHOLDERS have been prohibited from paying the installments with own resources other than dividends.
• The SHAREHOLDERS may unilaterally resolve the purchase and sale contract if they become aware of the existence or initiation of any judicial, administrative, labor, arbitral, bankruptcy, or any other type of process that falls directly or indirectly on the shares subject to the sale.

That, however, in the present case, the aforementioned resolutions with suspensive conditions are legal acts that would return the shares to DGF, which does not have economic solvency to be a shareholder of DIVISO SAF, according to what is established in Letters No. 1157-2025-SMV/10 and No. 1832-2025-SMV/10. Consequently, it would not be possible for DGF to request prior authorization to subscribe to these clauses;

3) EVALUATION OF SWORN DECLARATIONS OF ASSET INFORMATION

That, taking into account that the EVALUATED SHAREHOLDERS should be able to cover the purchase price of the shares of DIVISO SAF (S/ 9,301,000.00), this payment obligation will be contrasted with the available liquid assets that they have stated to possess in their ASSET DECLARATION;

That, likewise, it will be analyzed whether the EVALUATED SHAREHOLDERS have liquid assets for an amount greater than the equivalent to their percentage participation in the minimum social capital of DIVISO SAF, as detailed below:

Table No. 4
Contributions by shareholder of DIVISO SAF for compliance with minimum capital as of 2025

Minimum SAF Capital: S/ 1,804,746.00

SHAREHOLDER
PART. (%)
Reference Contribution
(Amounts weighted by shareholder participation) YÉSICA DEL CARPIO 10% S/180,474.60 NICOLE ESPINOZA 8% S/144,379.68

“Article 140.- The legal act is the manifestation of will destined to create, regulate, modify or extinguish legal relations. (...).”

PERU Ministry of Economy and Finance

SMV
Superintendencia del Mercado de Valores
Document electronically signed digitally under the framework of Law No. 27269, Law of Digital Signatures and Certificates, its Regulations and amendments. The integrity of the document and authorship EVELY HERRERA 8% S/144,379.68 ESPERANZA LIVELLI 10% S/180,474.60 JULIO PERALTILLA 10% S/180,474.60 DIEGO RODRIGUEZ 8% S/144,379.68 MIGUEL RODRIGUEZ 9% S/162,427.14 ENMA ROJAS 8% S/144,379.68

That, in the ASSET DECLARATION, information on the monthly income of the SHAREHOLDERS was collected, with the purpose of reviewing if they have the capacity to generate resources in a sustained manner and verifying that there is congruence between said capacity and the declared assets;

That, income from salaries and others has not been considered as assets, because they represent future cash flows, and are subject to uncertain conditions such as employment continuity, contractual changes, or other contingencies. Furthermore, these incomes, once received, may be reflected as savings or in their assets, which will be considered to determine the solvency of the EVALUATED SHAREHOLDERS;

That, additionally, jewelry and precious stones cannot be considered as liquid assets, for prudential purposes, because they do not have a title registration;

That, on the other hand, vehicles (cars, trucks, etc.), despite having market value, may require months to be sold, suffer constant depreciation and the potential sale is subject to individual negotiation. Likewise, in the case of real estate, despite being high-appreciation assets, their sale usually requires prolonged processes (months), in addition to the notarial and registry procedures it implies. On the other hand, paintings or pictures are artistic-type assets, their value is difficult to verify objectively, and their sale depends on the interest of specific third parties. Therefore, all assets described in this paragraph are considered non-liquid and, therefore, do not form part of the calculation of the economic solvency of the EVALUATED SHAREHOLDERS;

That, regarding debts or liabilities, within the framework of this evaluation, the declared information was contrasted with Experian credit reports, issued by Sentinel for each of the EVALUATED SHAREHOLDERS 14. In this way, the last available information has been considered based on the date of subscription of the ASSET DECLARATION and the date of information of the Experian report;

That, it must be highlighted that the criteria evaluated by the General Superintendent of Entities through Letter No. 3671-2025-SMV/10.2 are of a prudential nature. Averages or favorable cases for the realization of assets are not considered. This is reasonable, because shareholders of a company with operating authorization to capture public savings must clearly maintain their economic solvency. Considering averages or success cases would mean an imminent risk for the market;

14 Issued on June 18, 2025. Contains information as of April 2025.

PERU Ministry of Economy and Finance

SMV
Superintendencia del Mercado de Valores
Document electronically signed digitally under the framework of Law No. 27269, Law of Digital Signatures and Certificates, its Regulations and amendments. The integrity of the document and authorship That, on this point, in accordance with Letter No. 3671-2025-SMV/10.2, the shareholders: Yesica Ysabel Del Carpio, Nicole Alexandra Espinoza Rengifo, Evely Herrera Peña, Esperanza Teresa Livelli Bacigalupo, Julio Angel Peraltilla Fernandez Baca, Diego Jesús Rodríguez Torres, Miguel Angel Rodríguez Vargas and Enma Dabida Rojas Pomahuali, who represent 71% of the shares of the social capital of DIVISO SAF, do not have economic solvency. Therefore, it is noted that DIVISO SAF has not been able to prove the economic solvency of its shareholders, in accordance with what was required through letters No. 1157-2025-SMV/10 of February 26 and No. 1832-2025-SMV/10 of March 31, 2025;

Suspension of Operating Authorization

That, the suspension of the operating authorization of DIVISO SAF must be carried out in compliance with what is provided by article 3, subsection 14, literal ii), of the Unified Concordant Text of the Organic Law of the Securities Market Superintendence, approved by Decree Law No. 26126 and its amendments (hereinafter, ORGANIC LAW);

That, within the framework of the supervision of stockbroker companies, the regulations establish minimum requirements so that market participants can operate, in order to maintain balance and security in the activities they carry out with third parties;

That, in this context, shareholders of stockbroker companies must have, at all times, to the satisfaction of the SMV, economic solvency. This requirement stems from the need to have an implicit backing to the capital of said entities in case they face adverse economic situations and it is required that shareholders make capital contributions to absorb losses or comply with relevant prudential limits. Likewise, in subsection 3) above, the methodology used to analyze the economic solvency of the EVALUATED SHAREHOLDERS to acquire shares of a stockbroker company is described;

That, in accordance with OFFICE 719 of February 6, 2025, the IGSE communicated to DGF and ANDEAN EQUITY, direct and indirect shareholders, respectively, of DIVISO SAF, that they had ceased to have recognized economic solvency. This, in accordance with what is provided by articles 4 and 11-A of the COMMON RULES, and it was required to present the documentation that accredits the correction of the observed situation;

That, with Letter No. 1157-2025-SMV/10 of February 26, 2025, the SASP communicated to DIVISO SAF that, according to the SHAREHOLDERS' RESPONSE, the observations regarding DGF and ANDEAN EQUITY had not yet been corrected. Likewise, they were required that, within a period not exceeding thirty (30) calendar days, the situation of non-compliance referred to in OFFICE 719, regarding the economic solvency of the aforementioned shareholders, be reversed, and it be accredited, with the respective documentary support, that said situation was no longer maintained;

That, regarding this, DIVISO SAF, through a writing of March 26, 2025, requested an extension of one hundred eighty (180) calendar days for the correction of the observations referred to the fact that DGF and ANDEAN EQUITY had ceased to have recognized economic solvency;

That, on this point, through Letter No. 1832-2025-SMV/10, the SASP granted DIVISO SAF an extension of thirty (30) calendar days, which expired on April 30, 2025. Therefore, until that date it was necessary to accredit, with

PERU Ministry of Economy and Finance

SMV
Superintendencia del Mercado de Valores
Document electronically signed digitally under the framework of Law No. 27269, Law of Digital Signatures and Certificates, its Regulations and amendments. The integrity of the document and authorship the respective documentary support, that DGF and ANDEAN EQUITY had economic solvency, in accordance with the applicable regulations;

That, on the other hand, the IGSE with Letter No. 1794-2025-SMV/10.2 of March 28, 2025, required DIVISO SAF for information with the purpose of evaluating the impact that the facts described in the STRENGTHENING PLAN would have, which, as indicated in the LETTERS, would allow recovering the economic solvency of DGF and ANDEAN EQUITY;

That, however, DIVISO SAF, through a relevant event of April 29, 2025, informed about the transfer of all shares representing its social capital to the SHAREHOLDERS. It should be noted that DIVISO SAF informed, with a significant event of May 7, 2025, that Mr. José Augusto Domenack Casas transferred all the shares representing the social capital in his title in favor of Mrs. Esperanza Teresa Livelli Bacigalupo;

That, in this order of ideas, through OFFICE 3009 of May 26, 2025, it was required to DIVISO SAF to remit, among others, the sworn declaration of asset property of the SHAREHOLDERS, indicating if they are subject to any type of encumbrance or limitation for their free availability, as well as a list of their debts;

That, regarding this, DIVISO SAF responded to OFFICE 3009 through writings of June 4 and 5, 2025, attaching the ASSET DECLARATION of the SHAREHOLDERS and the OTHER SHAREHOLDERS;

That, through OFFICE 3447 of June 16, 2025, complementary information was required to DIVISO SAF regarding the OTHER SHAREHOLDERS;

That, we must highlight that through Letter No. 3671-2025-SMV/10.2 of July 4, 2025, it was communicated to DIVISO SAF that the economic solvency of the EVALUATED SHAREHOLDERS was analyzed, and it was concluded that they had not accredited having the necessary economic solvency to be a shareholder of DIVISO SAF;

That, it should be noted that it was not the object of Letter No. 3671-2025-SMV/10.2 to supervise if these shareholders comply with the moral solvency to be shareholders of DIVISO SAF;

That, consequently, it has been corroborated that DIVISO SAF has not corrected the observations regarding the economic solvency of the shareholders, direct and indirect, DGF and ANDEAN EQUITY, with the transfer of the shares from DGF to the EVALUATED SHAREHOLDERS. It should be noted that the period granted to DIVISO SAF by the SASP through Letter No. 1157-2025-SMV/10 and extended by Letter No. 1832-2025-SMV/10 for this correction has expired to date;

That, for the aforementioned reasons, in order to preserve the integrity of the capital market and, thereby, the interests of the clients of a stockbroker company, it is necessary to suspend the activities of those stockbroker companies and fund management companies, in cases where their shareholders do not meet the minimum requirements or conditions to perform as such. This suspension seeks to be a temporary measure to protect the interests of the clients and potential clients of these entities. This, in accordance with article 3, subsection 14, literal ii), of the ORGANIC LAW;

That, consequently, the suspension measure can only be lifted when DIVISO SAF demonstrates that its shareholders have the necessary economic solvency, to the satisfaction of the SMV, and comply with the minimum conditions and requirements to be shareholders of a mutual fund management company and investment funds, and, if applicable, obtain the authorization of the corresponding share transfers;

That, it should be noted that this decision must be evaluated regardless of whether the evaluation of the economic solvency of the OTHER SHAREHOLDERS continues; and,

Being in accordance with what is provided by article 3, subsection 14, literal ii), of the Unified Concordant Text of the Organic Law of the Securities Market Superintendence, approved by Decree Law No. 26126, as well as by article 12, subsection 6, of the Organization and Functions Regulation of the SMV, approved by Supreme Decree No. 216-2011-EF;

RESOLVES:

Article 1º.- Suspend the operating authorization granted to Diviso Fondos Sociedad Administradora de Fondos S.A. for having the following eight (8) shareholders, who represent 71% of its social capital:
Yésica Ysabel Del Carpio, Nicole Alexandra Espinoza Rengifo, Evely Herrera Peña, Esperanza Teresa Livelli Bacigalupo, Julio Ángel Peraltilla Fernandez Baca, Diego Jesús Rodríguez Torres, Miguel Ángel Rodríguez Vargas and Enma Dabida Rojas Pomahuali; over whom it has not been accredited that they have economic solvency, in accordance with article 11-A of the Common Rules to entities that require authorization for organization and operation of the SMV, approved by Resolution SMV No. 039-2016-SMV/01 and its amendments, and by virtue of what is provided in article 34 of the Regulation of Mutual Investment Funds and their Management Companies, approved by Resolution CONASEV No. 068-2010-EF/94 and its modifying norms and article 24 of the Regulation of Investment Funds and their Management Companies, approved by Resolution SMV No. 029-2024-SMV-01 and its modifying norms.

Article 2º.- The suspension of the operating authorization will remain in effect for a period of thirty (30) business days, unless Diviso Bolsa Sociedad Agente de Bolsa S.A. accredits that the shareholders referred to in articles 1° and 2° of this resolution have the necessary economic solvency, to the satisfaction of the Securities Market Superintendence; and, comply with the minimum requirements and conditions according to the regulations, in addition to obtaining the authorization of the corresponding share transfers, if applicable.

Article 3º.- Diviso Fondos Sociedad Administradora de Fondos S.A. must comply with informing the Securities Market Superintendence, the day following the execution of the measure ordered in article 1° of this resolution and under responsibility, the information that the Securities Market Superintendence requests.

Article 4º.- Designate the president of the board of directors of Diviso Fondos Sociedad Administradora de Fondos S.A., Mr. Julio César Kanashiro Tome, as the person responsible for safeguarding the correct administration, custody and management of the assets, guarantees, documents, information and any rights corresponding to Diviso Fondos Sociedad Administradora de Fondos S.A. This designation may be modified by a resolution issued by the Adjunct Superintendent of Prudential Supervision.

Article 5º.- The suspension measure disposed of does not exempt Diviso Fondos Sociedad Administradora de Fondos S.A. from compliance with the obligations contracted in the market prior to the suspension decreed, nor from compliance with said obligations during the suspension period, in what is pertinent.

Article 6º.- The measure disposed of does not exempt the shareholders, directors or managers of Diviso Fondos Sociedad Administradora de Fondos S.A. from administrative responsibility incurred during the operation of the referred societies.

Article 7º.- Publish this resolution on the Institutional Page of the Securities Market Superintendence on the unique digital platform of the Peruvian State (www.gob.pe/smv).

Article 8º.- This resolution will enter into force on the day of its notification to Diviso Fondos Sociedad Administradora de Fondos S.A.

Article 9º.- Transcribe this resolution to Diviso Fondos Sociedad Administradora de Fondos S.A., to CAVALI S.A. ICLV and to Lima Stock Exchange S.A.

Register, communicate and publish.

Zósimo Juan Pichihua Serna
Superintendent of the Securities Market