Petroperú clarifies information regarding the investigation conducted by the Paul Hastings law firm

Regarding the information recently broadcast by the program *Punto Final* on Latina Televisión concerning the services provided by the Paul Hastings LLC law firm, Petroperú wishes to inform the public of the following:

1. The investigation began in 2022, following the public disclosure that Mr. Raymond Kohutt, of Gunvor S.A., had admitted to the U.S. Department of Justice that he had paid bribes to Petroecuador officials. Against this backdrop, and as a preventive measure, Petroperú engaged the international law firm Paul Hastings LLC to conduct an investigation and assess corruption risks associated with commercial dealings with Gunvor and Vitol between 2015 and 2021.
2. The final report issued by Paul Hastings LLC in May 2025 concluded that there was no clear evidence of *quid pro quo* (bribery) or violations of the U.S. Foreign Corrupt Practices Act (FCPA); it further determined that there were no indications of criminal conduct, agreements to rig tenders, or preferential treatment shown to Gunvor or Vitol by Petroperú personnel.
3. In this regard, Petroperú emphasizes that the reports prepared by Paul Hastings LLC are strictly protected by legal privilege (U.S. attorney-client privilege). Consequently, the public disclosure of this document by the previous administration compromised that legal privilege.
4. Concurrently, Audit Report No. 003-2023-2-0084-AC—issued in 2023 by the Institutional Control Body (OCI) of the Office of the Comptroller General regarding contracts with Gunvor (2013–2021)—likewise found no evidence of administrative, civil, or criminal liability on the part of the Company’s employees.
5. In response to recommendations made by both the OCI and the specialized study, the Company has implemented rigorous remediation measures aimed at continuously strengthening its institutional mechanisms for preventing corruption (including MLTF and bribery).
6. Petroperú reaffirms its commitment to integrity, transparency, and the continuous strengthening of its prevention and control mechanisms, as well as to the responsible handling of information and compliance with regulations governing the treatment of information protected by legal privilege.

The company will continue to drive initiatives aimed at strengthening its processes, addressing identified opportunities for improvement, and preventing conduct contrary to its values and the prevailing regulatory framework.