Correspondence 0001104659-23-102149 from MOBILE TELESYSTEMS PUBLIC JOINT STOCK Co (CIK 0001115837)
MOBILE TELESYSTEMS PUBLIC JOINT STOCK Co (CIK 0001115837)
Date: Sept. 20, 2023 · CIK: 0001115837 · Accession: 0001104659-23-102149
AI Filing Summary & Sentiment
File numbers found in text: 001-15094
Letter
September 20, 2023
BY EDGAR
Division of Corporation Finance
Securities and Exchange Commission
Washington, D.C. 20549
United States of America
Attention: Joseph Kempf
Robert Littlepage
Re: Mobile TeleSystems Public Joint Stock Company
Form 20-F for Fiscal Year Ended December 31,
Filed April 17, 2023
File No. 001-15094
Ladies and Gentlemen:
On behalf of Mobile TeleSystems Public Joint Stock Company (the “Company” or “MTS”), we hereby transmit the Company’s response to the comment letter received from the staff (the “Staff”) of the U.S. Securities and Exchange Commission (the “SEC”), dated September 8, 2023, regarding MTS’s Annual Report on Form 20-F for Fiscal Year Ended December 31, 2022 (the “2022 Annual Report”) filed on April 17, 2023.
For the Staff’s convenience, we have repeated below the Staff’s comment in italics, and have followed such comment with MTS’s response.
Form 20-F for Fiscal Year Ended December 31,
Independent Auditor's Report, page F-3
1. We note that the audit report states that the Mobile TeleSystems PJSC and its subsidiaries (the “Group”) financial statements were audited in accordance with International Standards on Auditing. Please revise your filing to include an audit report that complies with Instruction 2 to Item 8.A.2 of Form 20-F, which indicates that the financial statements of the issuer must be audited in accordance with the Standards of the Public Company Accounting Oversight Board (“PCAOB”). In this regard, we note that on page 160 of your Form 20-F, you include the audit report on the internal control over financial reporting of the Group as of December 31, 2022, and that opinion also refers to an audit, in accordance with the standards of the PCAOB, on the consolidated financial statements of the Group for the year ended December 31, 2022.
Response:
We note the Staff’s comment. As disclosed in the 2022 Annual Report, the Group’s consolidated financial statements as of and for the year ended December 31, 2022 were prepared in accordance with International Financial Reporting Standards (IFRS) as issued by the International Accounting Standards Board, and were audited in accordance with both International Standards on Auditing (“ISAs”) and the standards of the Public Company Accounting Oversight Board (United States) (the “PCAOB”). The 2022 Annual Report, as originally filed, inadvertently contained an audit report of AO “Business Solutions and Technologies”, the Group’s Independent Registered Public Accounting Firm, which referred only to an audit conducted in accordance with ISAs.
In response to the Staff’s comment, the Company has filed Amendment No. 1 to the 2022 Annual Report on September 14, 2023, solely for the purpose of including the correct form of audit report of the Company’s Independent Registered Public Accounting Firm referring to such firm’s audit conducted in accordance with the standards of the PCAOB.
*****
«Mobile TeleSystems» Public Joint-Stock Company
4, Marksistskaya str., Moscow, Russia, 109147. Tel. +7 (495) 911 71 51, fax +7 (495) 911 65 69, www.mts.ru
We confirm that we are aware that MTS and its management are responsible for the accuracy and adequacy of the Company’s disclosures, notwithstanding any review, comments, action or absence of action by the Staff.
Thank you for your prompt attention to the Company’s response to the Staff’s comment. If you have any further questions, please contact Investor relations department (ir@mts.ru, +7 495 223 2025), to assist you as required.
Very truly yours,
/s/ Andrey Kamenskiy
Show Raw Text
CORRESP 1 filename1.htm September 20, 2023 BY EDGAR Division of Corporation Finance Securities and Exchange Commission Washington, D.C. 20549 United States of America Attention: Joseph Kempf Robert Littlepage Re: Mobile TeleSystems Public Joint Stock Company Form 20-F for Fiscal Year Ended December 31, 2022 Filed April 17, 2023 File No. 001-15094 Ladies and Gentlemen: On behalf of Mobile TeleSystems Public Joint Stock Company (the “Company” or “MTS”), we hereby transmit the Company’s response to the comment letter received from the staff (the “Staff”) of the U.S. Securities and Exchange Commission (the “SEC”), dated September 8, 2023, regarding MTS’s Annual Report on Form 20-F for Fiscal Year Ended December 31, 2022 (the “2022 Annual Report”) filed on April 17, 2023. For the Staff’s convenience, we have repeated below the Staff’s comment in italics, and have followed such comment with MTS’s response. Form 20-F for Fiscal Year Ended December 31, 2022 Independent Auditor's Report, page F-3 1. We note that the audit report states that the Mobile TeleSystems PJSC and its subsidiaries (the “Group”) financial statements were audited in accordance with International Standards on Auditing. Please revise your filing to include an audit report that complies with Instruction 2 to Item 8.A.2 of Form 20-F, which indicates that the financial statements of the issuer must be audited in accordance with the Standards of the Public Company Accounting Oversight Board (“PCAOB”). In this regard, we note that on page 160 of your Form 20-F, you include the audit report on the internal control over financial reporting of the Group as of December 31, 2022, and that opinion also refers to an audit, in accordance with the standards of the PCAOB, on the consolidated financial statements of the Group for the year ended December 31, 2022. Response: We note the Staff’s comment. As disclosed in the 2022 Annual Report, the Group’s consolidated financial statements as of and for the year ended December 31, 2022 were prepared in accordance with International Financial Reporting Standards (IFRS) as issued by the International Accounting Standards Board, and were audited in accordance with both International Standards on Auditing (“ISAs”) and the standards of the Public Company Accounting Oversight Board (United States) (the “PCAOB”). The 2022 Annual Report, as originally filed, inadvertently contained an audit report of AO “Business Solutions and Technologies”, the Group’s Independent Registered Public Accounting Firm, which referred only to an audit conducted in accordance with ISAs. In response to the Staff’s comment, the Company has filed Amendment No. 1 to the 2022 Annual Report on September 14, 2023, solely for the purpose of including the correct form of audit report of the Company’s Independent Registered Public Accounting Firm referring to such firm’s audit conducted in accordance with the standards of the PCAOB. ***** «Mobile TeleSystems» Public Joint-Stock Company 4, Marksistskaya str., Moscow, Russia, 109147. Tel. +7 (495) 911 71 51, fax +7 (495) 911 65 69, www.mts.ru We confirm that we are aware that MTS and its management are responsible for the accuracy and adequacy of the Company’s disclosures, notwithstanding any review, comments, action or absence of action by the Staff. Thank you for your prompt attention to the Company’s response to the Staff’s comment. If you have any further questions, please contact Investor relations department (ir@mts.ru, +7 495 223 2025), to assist you as required. Very truly yours, /s/ Andrey Kamenskiy Andrey Kamenskiy Chief Financial Officer Mobile TeleSystems Public Joint Stock Company cc: Timothy Corbett, Morgan Lewis & Bockius LLP «Mobile TeleSystems» Public Joint-Stock Company 4, Marksistskaya str., Moscow, Russia, 109147. Tel. +7 (495) 911 71 51, fax +7 (495) 911 65 69, www.mts.ru