Office of the Chairman Council of Ministers INDECOPI BANKRUPTCY PROCEDURES COMMITTEE five hundred ten

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1 0510 five hundred ten RESOLUTION No /CCO CASE No /CCO DEBTOR : DOE RUN PERÚ, S.R.L. (DOE RUN) CREDITOR : ACTIVOS MINEROS S.A.C. (ACTIVOS MINEROS) ISSUE : GROUNDLESS RECOGNITION OF CLAIMS ORIGIN : COMMERCIAL CLAIM Lima, February 2, 2011 I. RECITALS Doe Run s bankrupt status was published on August 16, On September 27, 2010 Activos Mineros filed for recognition of claims totaling US$ 10,500, for principal, arising from an estimate of Doe Run s percentage share in the obligations for remediation of soil adversely affected by the La Oroya Metallurgical Complex s emissions, according to studies performed by the Gwi E Intrinsic Risk consulting firm. In support of that action, Activos Mineros alleged the following: 1. By Public Deed containing the Share Transfer, Increase of Capital, and Subscription of Shares Contract of October 23, 1997 (hereinafter the Share Transfer Contract), Empresa Minera del Centro del Perú S.A. Centromin Perú S.A. (hereinafter Centromin Perú) transferred ownership of the shares of the Empresa Metalúrgica La Oroya S.A. Metaloroya S.A. (hereinafter, Metaloroya) to Doe Run. 2. The fifth clause of the Share Transfer Contract regulated the circumstances in which Metaloroya would be liable for damages, losses, and third-party claims attributable to it commencing as of the date on which the contract was signed. 3. On December 30, 1997 Doe Run merged with Metaloroya, absorbing all its assets and liabilities and replacing it in all the rights and obligations prescribed in the Share Transfer Contract 2. 1 Deadline for timely submission of requests for recognition of claim: September 28, Pursuant to the first clause of the Public Deed of December 27, 1999, amending the Share Transfer Contract, a copy of which is on file in the record, the Doe Run Perú S.R.L. company absorbed Metaloroya S.A. and the latter company was dissolved without liquidation, by the Public Deed of Merger dated December 30, 1997, executed before Notary Aníbal Corvetto Romero. By virtue of the assignment, Doe Run assumed the rights and obligations of Metaloroya S.A.

2 0511 five hundred eleven 4. By Resolution No MEM-DGM/V, the Directorate General of Mining, of the Ministry of Energy and Mines, approved Report No MEM-DGM-FMI/MA, which contains the report on the Special Examination of the La Oroya Metallurgical Complex, whose section 4.3 specifies Centromin Perú s obligations in regard to the Replanting of Areas Adversely Affected by Smoke project. 5. By Ministerial Resolution No MEM/DM of May 29, 2006, the Ministry of Energy and Mines partially approved the exceptional extension request for the Sulfuric Acid Plants Project of the Metaloroya PAMA (Environmental Remediation and Management Plan) (now the Doe Run PAMA). Article 10 of said resolution provided that the extension did not imply any modification of the obligations or time limits prescribed in the contracts Doe Run had executed with Centromin Perú and the Peruvian States. 6. By Supreme Decree No EM of October 4, 2006, the Peruvian State entrusted Activos Mineros with the conduct and execution of the PAMA s environmental remediation projects, as well as Activos Mineros subrogation in the contracts executed with Centromin Perú. 7. Through the Contractual Position Assignment Contract of March 19, 2007, Activos Mineros assumed Centromin Perú s rights and obligations arising from the execution of the PAMA which in turn derived from the Share Transfer Contract. 8. In compliance with Supreme Decree No EM, the Gwi E Intrinsic Risk (GWI) international consulting firm was retained to perform the Study of Health and Ecological Risk, and Remediation Measures for the Soils Contaminated by Smoke from the La Oroya Metallurgical Complex, with the aim of determining area contaminated by the project s emissions, the level of risk posed thereby, and the remediation measures required for its rehabilitation. 9. The estimate of Doe Run s share in the remediation of the soil adversely affected by emissions from the La Oroya Metallurgical Complex was determined on the basis of the emissions, concentration of affected soils, and health risk factors. 10. The estimate used to determine the percentage of liability was made by combining the aforementioned three factors and assigning weightings of four (4) to the emissions, one (1) to the concentration, and one (1) to the health risk, yielding the following results:

3 0512 five hundred twelve Company Emissions Factor Soil Concentration Factor Health Risk Factor Degree of Liability Investment in US$ Cerro de Pasco Corporation 84% 36% 20% 65% 19,500, Centromin Perú Doe Run 16% 64% 80% 35% 10,500, Total 100% 100% 100% 100% 30,000, The percentage share of liability for the replanting project in the areas adversely affected by the smoke emissions implies a minimum investment of US$ 10,500, by Doe run, as well as a liability for it whose value is incalculable, arising from operations by Doe Run that resulted in damage to the population s health, pursuant to Clause 5.3 of the Share Transfer Contract. 12. Doe Run has failed to execute the Metaloroya PAMA, thereby becoming subject to the liability emanating from the Share Transfer Contract. On December 2, 2010 Doe Run opposed the claims invoked, arguing as follows: 1. Activos Mineros has alleged that: a) it has no longer borne the soil remediation obligation since 1998; b) said obligation lies with Doe Run due to its breach of the Environmental Remediation and Management Plan (PAMA); c) said obligation can be valued in monetary terms and its value has been determined by a specialized company; and d) said obligation is owed to Activos Mineros by Doe Run. 2. However, a) it is Activos Mineros which owes the soil remediation obligation to the Peruvian State; b) Doe Run has not breached its PAMA, and even if it had done so, that would not generate any obligation toward Activos Mineros, and c) the soil remediation obligation s purpose is protection of the environment, which originates in law, cannot be renounced, disposed of, or divested, and is accordingly impossible to value. 3. Mineros Activos was incorporated into the relationship originally established between Centromin Perú and Doe Run by Supreme Decree No EM of October 4, 2006, pursuant to which Activos Mineros is the party responsible for the soil remediation work. 4. Pursuant to section 1, part c), of the Share Transfer Contract s sixth clause, the contractual obligation to remedy the polluted areas lies with Centromin Perú (subrogated by Activos Mineros).

4 0513 five hundred thirteen 5. There is no breach of the PAMA, since it would have to be declared by the competent authority. The term for completing the PAMA was modified, first by Ministerial Resolution No MEM/DM, which extended the term for completing the PAMA to 2009, and second by Law No , which further extended the term to April 27, In the hypothetical and denied event that a breach of the PAMA were determined to have occurred, Activos Mineros would only be empowered to excuse itself from soil remediation obligation from the date on which said breach was declared, and to excuse itself from bearing liability toward third parties for claims arising from pollution provoked by Doe Run; accordingly, in no case would it be entitled to demand the payment of any sum of money, or even to demand compliance with the PAMA, since the authority to do so is vested in the Agency for Environmental Assessment and Oversight OEFA (OEFA). 7. The US$ 10,500, figure reflected in the study and unilaterally distributed by Activos Mineros lacks both the legal validity to determine the amount of an obligation and the jurisdiction to declare the existence of an obligation. 8. The soil remediation obligation does not qualify as a claim, and Activos Mineros does not qualify as a creditor in bankruptcy, lacking the standing to take action. 9. Soil remediation projects (such as PAMAs) do not constitute a right to make a claim; rather, their purpose is for the entities responsible for mining activity to reduce their levels of environmental pollution. 10. Soil remediation is not an obligation for the benefit of Activos Mineros, but an obligation to be overseen by the Peruvian State through the OEFA, which arose from the Share Transfer Contract and must be fulfilled by Centromin Perú (subrogated by Activos Mineros). By a brief dated January 11, 2011, complemented on January 19, 2011, Activos Mineros additionally argued as follows: 1. Pursuant to the provisions of Clause 5.3, part a), of the Share Transfer Contract, during the period approved for the execution of the Metaloroya PAMA or the Doe Run PAMA (October 23, 1997 to January 13, 2007), the bankrupt company produced more pollution than had been produced during Centromin Peru s period of operation, which is an act not related to the PAMA, wherefore the liability for it is attributable to Doe Run.

5 0514 five hundred fourteen 2. Doe Run is liable for the second stage of pollution and environmental damage produced from October 23, 1997 to the present, because it breached the PAMA and due to the worse operating practices applied by the bankrupt company, pursuant to Article 5.4 of the Share Transfer Contract. 3. Pursuant to Clause 6.2 of the Share Transfer Contract, Centromin Perú (subrogated by Activos Mineros) would assume the liability for environmental damage only if Doe Run were not liable for said damage. 4. The requested claims arise from co-liability for the damage done to the environment in the areas identified in the Study of Health and Ecological Risk, and Remediation Measures for the Soils Contaminated by Smoke from the La Oroya Metallurgical Complex and the more recent damage adversely affecting the population, for which Doe Run is liable as prescribed in Clauses 5.3 and 5.4 of the Share Transfer Agreement, stemming from the smoke emissions from the La Oroya Plant and unrelated to the execution of the Doe Run PAMA. 5. Accordingly, the origin of the claims invoked is not only a consequence of breach of the PAMA but also of the application of practices less protective of the environment than those previously in use by Centromin Perú and its predecessors. 6. Activos Mineros is responsible for the soil remediation obligation pursuant to Clause 6 of the Share Transfer Contract, but there are exceptions according to Clauses 6.1 and 6.2, which are provided for in Clauses 5.3 and 5.4 of said contract. 7. Activos Mineros acknowledges that it bears the soil remediation obligation up to 65% of the total investment necessary to carry out the project, but Doe Run is responsible for 35% of said obligations. 8. Pursuant to Ministerial Resolution No MEM/DGM of May 29, 2006, an exceptional term was granted for the Doe Run PAMA, which is of an administrative but not a contractual nature, and accordingly, for all intents and purposes October 23, 1997 must be taken as the PAMA s commencement date and January 13, 2007 as its date of finalization. 9. The Share Transfer Contract of October 23, 1997 is a privatization contract which has the nature of a contract-law.

6 0515 five hundred fifteen 10. The legal right to demand recognition of claims stems from Supreme Decree No EM, whereby the State delegated the conduct and execution of the environmental remediation projects to it. 11. The Study of Health and Ecological Risk, and Remediation Measures for the Soils Contaminated by Smoke from the La Oroya Metallurgical Complex was carried out in compliance with Decree No EM. 12. The soil remediation obligation is an obligation to take action which is quantifiable by virtue of the Study of Health and Ecological Risk, and Remediation Measures for the Soils Contaminated by Smoke from the La Oroya Metallurgical Complex and Articles 5.3 and 5.4 of the Share Transfer Contract. II. THE QUESTION AT ISSUE To determine, with attention to the opposition that has been raised, whether it is valid to recognize the claims invoked, and in that event, to indicate the order of priority thereof and the debtor s liability for them. III. ANALYSIS OF THE QUESTION AT ISSUE III.1 The Share Transfer Contract A copy of the Public Deed containing the Share Transfer Contract of October 23, 1997, whereby Centromin Perú transferred % of the shares representing Metaloroya s capital stock to Doe Run, is on file in the record, as is a copy of the public deed of Amendment of the Share Transfer, Increase of Capital, and Subscription of Shares Contract dated December 27, 1999, whereby Centromin Perú and Doe Run agreed to amend Clauses 5.1, 5.2, and 6.1 of the Contract of October 23, Metaloroya (THE COMPANY) and Centromin Perú (CENTROMIN) agreed as follows in the fifth and sixth clauses of the Contract and its amendment; FIFTH CLAUSE. THE COMPANY S LIABILITY IN ENVIRONMENTAL AFFAIRS CENTROMIN and THE COMPANY acknowledge that the Environmental Remediation and Management Plan (PAMA) for CENTROMIN PERÚ s La Oroya Production Unit, which was approved by Board Resolution No EM/DGM of January 13, 1997 and amended by Board Resolution No EM/DGM of October 6, 1997, has been divided into the METALOROYA S.A. Environmental Remediation and Management Plan (PAMA) for the La Oroya Metallurgical Complex (hereinafter the METALOROYA

7 0516 five hundred sixteen PAMA ), which was approved by Board Resolution No EM/DGM of October 16, 1997, and the CENTROMIN PERÚ S.A. Environmental Remediation and Management Plan (PAMA) for La Oroya (hereinafter the CENTROMIN PAMA ), which was approved by Board Resolution No EM/DGM of October 16, THE COMPANY assumes responsibility exclusively in regard to the following environmental issues: 5.1 The fulfillment of the obligations prescribed in the METALOROYA PAMA and its eventual amendments approved in conformity with the provisions of law in force which have been or are in the future issued by the competent authority in relation to the effluents, emissions, and residues. 5.2 The future closure and dismantling at the conclusion of their operational life of: a) THE COMPANY s smelting and refining installations. b) The slag deposit. c) The zinc ferrite deposits. 5.3 During the period approved for the METALOROYA PAMA s execution, THE COMPANY shall assume liability for damages, losses, and third-party claims attributable to it from the date of this contract s signing forward, exclusively in the following cases: a) Those arising directly due to acts not related to the METALOROYA PAMA and attributable exclusively to THE COMPANY, but only insofar as said acts are consequences of THE COMPANY s application of standards and practices that are less protective of the environment or public health than those which were followed by CENTROMIN up to the date on which this contract is signed. In the event of a dispute over the determination of whether the standards or practices used by THE COMPANY have or have not been less protective of the environment or public health than those applied by CENTROMIN, and if no agreement is reached within the thirty (30) calendar days from the date on which the claim was received, CENTROMIN and THE COMPANY shall submit said determination to the opinion of an expert, following the procedure stipulated in Section 5.4.C to that end. b) Those arising directly from THE COMPANY s breach of the METALOROYA PAMA s obligations, or of the obligations prescribed by this contract in sections 5.1 and Following the expiration of the METALOROYA PAMA s legal term, THE COMPANY shall assume liability for damages, losses, and third-party claims as follows:

8 0517 five hundred seventeen a) Those arising directly from acts which are exclusively attributable to its operations subsequent to said period. b) Those arising directly from THE COMPANY s breach of the METALOROYA PAMA s obligations, or of the obligations prescribed by this contract in sections 5.1 and 5.2. c) In the event the damages and losses are attributable to both CENTROMIN and THE COMPANY, THE COMPANY shall bear liability in proportion to its contribution to the damage. In cases where there is no consensus between CENTROMIN and THE COMPANY regarding the causes and alleged damage to which the claim refers, or the proportions in which the liability should be distributed between them, and if no agreement is reached by the expiration of thirty (30) days from the date on which the claim is received, the issue shall be submitted to decision by an expert in the subject matter, to be designated by mutual agreement, who must issue his decision as quickly as possible. If the amount of the claim is less than US$ 50,000.00, CENTROMIN and THE COMPANY shall be obligated to abide by the expert s decision. If the amount of the claim exceeds US$ 50,000.00, CENTROMIN and THE COMPANY may submit the issue to arbitration in conformity with the twelfth clause of this contract, if one or both parties disagree with the expert s decision. 5.5 From the date on which this contract is signed forward, THE COMPANY shall not have or assume any liability for damages or losses, nor for third-party claims, attributable to CENTROMIN, insofar as they are the outcome of the operations of CENTROMIN and its predecessors up to the date on which this contract is signed, or are due to CENTROMIN s breach of the obligations specified in Section If THE COMPANY returns the zinc ferrite deposits to which reference is made in Section 5.1.C to CENTROMIN, it must pay the latter US$ 7,200, (seven million two hundred thousand United States dollars) for the cost of remediation thereof, and CENTROMIN shall thereupon assume sole liability for them and shall indemnify and hold THE COMPANY harmless against any claim, cost, lawsuit, or other obligation referring thereto. 5.7 CENTROMIN reserves the right to perform the inspections which may be necessary to verify compliance with the provisions of Section 5.1.C. 5.8 THE COMPANY shall safeguard and hold CENTROMIN harmless against third-party claims and shall indemnify it for any damage, liability, or

9 0518 five hundred eighteen obligation which may supervene and for which it has assumed a responsibility and obligation. 5.9 All other liabilities shall remain with CENTROMIN pursuant to the sixth clause. SIXTH CLAUSE. CENTROMIN S RESPONSIBILITY IN ENVIRONMENTAL AFFAIRS 6.1 CENTROMIN assumes responsibility for the following environmental affairs: a) Compliance with the CENTROMIN PAMA as it may be amended with approval by the competent authority and the applicable legal requirements that have been or are in the future adopted by the competent authority. b) Technical abandonment of the arsenic trioxide deposits in existence on the date when this contract is signed and the obligations related thereto, including the additional residues deposited in them by THE COMPANY in areas where this is permitted in conformity with the fifth clause. c) Remediation of the areas affected by the gaseous and particulate matter emissions from the smelting and refining operations, emitted up to the date on which this contract is signed, and additional emissions during the period provided by law for the METALOROYA PAMA, except for THE COMPANY s areas of responsibility pursuant to the fifth clause. d) Technical abandonment of the zinc ferrite deposits and the obligations related thereto, if THE COMPANY returns them to CENTROMIN within a term of three (3) years from the date on which this contract is signed and pays the sum stipulated in section 5.6. e) Remediation and technical abandonment of any deposit of residues generated by CENTROMIN or its predecessors prior to the date of the La Oroya Metallurgical Complex s transfer, not identified or whose existence has not been declared prior to the date of said transfer. 6.2 During the period approved for the METALOROYA PAMA s execution, CENTROMIN shall assume liability for any damages, losses, or third-party claims attributable to the activities of THE COMPANY, CENTROMIN, and/or their predecessors, except for the damages, losses, and third-party claims for which THE COMPANY is liable pursuant to section After the expiration of the METALOROYA PAMA s legal term, CENTROMIN shall assume liability for any damages and third-party claims attributable to the activities of CENTROMIN and/or its predecessors, except for the damages, losses, and third-party claims for which THE COMPANY is liable pursuant to section 5.4.

10 0519 five hundred nineteen In the event the damages and losses are attributable to both CENTROMIN and THE COMPANY, the provisions of section 5.4.c) shall be applicable. 6.4 THE COMPANY reserves the right to perform the inspections which may be necessary to verify the CENTROMIN PAMA s execution. 6.5 CENTROMIN shall safeguard and hold THE COMPANY harmless against third-party claims and shall indemnify it for any damage, liability, or obligation which may supervene and for which it has assumed a responsibility and obligation. III.2 Definition of claim in bankruptcy Activos Mineros alleges that Doe Run breached the PAMA and that the circumstances provided for in sections 3 and 4 of the Share Transfer Contract s fifth clause were found to exist, wherefore the bankrupt party must bear part of the liability for the execution of the Remediation of Soil Adversely Affected by Emissions from the La Oroya Metallurgical Complex project. The total investment for the soil remediation project s execution, according to the study performed by an international consultant, comes to US$ 30,000,000.00, of which Doe Run must bear a cost of US$ 10,500,000.00, equivalent to 35% of the total value, and Activos Mineros is responsible for the remainder, amounting to US$ 19,500, It was stipulated in Clause 5.3 of the Share Transfer Contract that, during the period of the Doe Run PAMA s execution, the bankrupt party would be liable for damages, losses, and third-party claims in the following cases: 1) those not related to the PAMA and attributable to it, when it has applied practices less protective of the environment than those applied by Centromin Perú up to the date on which the contract was signed; 2) those arising directly from a breach of the Doe Run PAMA; or 3) Those arising from a breach of Doe Run s obligations as prescribed in Clause 5.1 (relating to effluents emissions, and residues) and Clause 5.2 (referring to the closure and dismantling of the installations or deposits). Clause 5.4 of the Share Transfer Contract provides that following the PAMA s expiration, Doe Run will be liable for damages, losses, and third-party claims in the following circumstances: 1) those generated by its operations subsequent to said period; 2) those arising directly from a breach of the PAMA, the contract, or the obligations prescribed in Clauses 5.1 and 5.2; and 3) when the damage is attributable to Centromin Perú and Doe Run, the bankrupt party shall bear the liability in the proportion pertaining to it. Clause 5.5 of the Share Transfer Contract provided that Doe Run shall not bear any liability whatsoever for damages, losses, and

11 0520 five hundred twenty third-party claims arising from the operations of Centromin Perú and its predecessors up to the date on which the Share Transfer Contract was signed. Pursuant to Clause 6.2 of the Share Transfer Contract, during the period of the Doe Run PAMA s execution, Activos Mineros would assume liability for damages, losses, and third-party claims for the activities of Doe Run, Centromin Perú, and/or their predecessors, except in the cases regulated in Article 5.3 of said contract. Subsequent to the Doe Run PAMA s expiration, Activos Mineros would assume the liability of Doe Run, Centromin Perú, and/or their predecessors, except in the cases regulated in Article 5.4 of the aforementioned contract. On this score, Article 1 of the General Law of the Bankruptcy System defines a claim as the creditor s right to obtain a performance, assumed by the debtor as a consequence of a binding legal relationship. However, the Share Transfer Contract only stipulates the obligations for which Metaloroya (now Doe Run) and Centromin Perú (subrogated by Activos Mineros) are responsible in relation to the environmental activities in which those companies were required to engage, which included compliance with the Doe Run PAMA and the Centromin Perú PAMA, respectively, as well as regulation of the cases in which said companies would assume liability for damages, losses, and third-party claims attributable to each of them or to both. Accordingly, it has not been demonstrated that, on the basis of the Share Transfer Contract, the bankrupt party was obligated to assume the obligations prescribed in that contract or the consequences of a breach thereof vis-à-vis Activos Mineros, nor has it been demonstrated that it was obligated to bear 35% of the total investment for soil remediation and that Doe Run is responsible to Activos Mineros for such investment, in conformity with the provisions of Article 1 of the General Law of the Bankruptcy System. Activos Mineros also alleged that the right to demand recognition of claims arises from Supreme Decree No EM, whereby the State delegated the conduct and execution of the environmental remediation projects, by virtue of which the Study of Health and Ecological Risk, and Remediation Measures for the Soils Contaminated by Smoke from the La Oroya Metallurgical Complex was performed.

12 0521 five hundred twenty-one It was stipulated by Supreme Decree No EM, published on October 14, 2006, that Activos Mineros subrogated itself in the contracts which had been executed by CENTROMIN PERU: Article 1. Amendment of Article 3 of Supreme Decree No EM. Article 3 of Supreme Decree No EM is amended so as henceforth to read as follows: Article 3. Circumstances in which the State assumes the execution of PAMA projects and projects for the closure or environmental remediation of CENTROMIN PERÚ and other state-owned enterprises. If the private investment promotion process in the projects arising from the so-called PAMAs does not conclude satisfactorily due to an absence of bidders or for other reasons, and the maximum terms prescribed for said process have expired, the State shall assume the environmental remediation obligations by contracting for the construction works, goods, and services which may be required. Article 2. Participation of ACTIVOS MINEROS S.A.C. In the circumstances to which Article 3 of Supreme Decree No EM refers, when the responsibility for said projects execution lies with CENTROMIN PERÚ S.A. or other State-owned enterprises subject to the scope of the private investment promotion process, the ACTIVOS MINEROS S.A.C. company shall directly assume the conduct of said activities execution. The responsibility of ACTIVOS MINEROS S.A.C. in this provision s application pertains only to the timely and effective execution of the aforementioned PAMA, closure, and environmental remediation projects, provided sufficient resources for their execution are on hand. ACTIVOS MINEROS S.A.C. shall subrogate itself in the contracts that have been executed by CENTROMIN PERÚ S.A. for the execution, supervision, monitoring, and maintenance of the PAMA, closure, or environmental remediation projects in question that have been retained or for whose execution under any mode said company was responsible prior to the date on which this provision is adopted. Article 5. Approval and oversight of environmental remediation projects The PAMA, closure, or environmental remediation projects to which this supreme decree refers shall be subject to approval by the Directorate General of Mining Environmental Affairs and shall be subject to the regular oversight process carried out by the competent organs. The legal provision cited above demonstrates only that Activos Mineros assumed the execution of the Centromin Perú PAMA, as well as the other obligations prescribed in the sixth clause of the Share Transfer Contract for which said company had been responsible.

13 0522 five hundred twenty-two Consequently, neither has it been demonstrated that, by virtue of Supreme Decree No EM, Doe Run must provide any performance vis-à-vis Activos Mineros arising from the Share Transfer Contract, wherefore in conformity with Article 1 of the General Law of the Bankruptcy System, the existence of a legal relationship that generates obligations for the bankrupt party vis-àvis Mineros Activos has not been demonstrated. In accordance with the foregoing, it is appropriate to declare the request to be groundless in conformity with Articles 1, 15.1, 37, and 39 of the General Law of the Bankruptcy System. IV. RESOLUTION To declare the request for recognition of claims filed by Activos Mineros S.A.C. to be groundless. With the intercession of Messrs. Amanda Velásquez de Rojas, Fernando Tori Tori, Carmen Padrón Freundt, and Fernando Sarria Arenas. [signature] AMANDA VELÁSQUEZ DE ROJAS Chairperson