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Correspondence 0001193125-23-185282 from EQUINOR ASA (EQNR, STOHF) (CIK 0001140625) (EQNR)

EQUINOR ASA (EQNR, STOHF) (CIK 0001140625)
Date: July 11, 2023 · CIK: 0001140625 · Accession: 0001193125-23-185282

AI Filing Summary & Sentiment

File numbers found in text: 001-15200

Referenced dates: June 21, 2023, June 30, 2023

Date
July 11, 2023
Author
/s/ May-Kirsti Enger
Form
CORRESP
Company
EQUINOR ASA (EQNR, STOHF) (CIK 0001140625)

Letter

Via EDGAR Division of Corporation Finance Form 20-F for Fiscal Year Ended December 31, 2022 Filed March 23, 2023 Response dated June 21, 2023 File No. 001-15200

Dear Mr. Klinko,

Thank you for your letter dated June 30, 2023, setting forth comments of the staff (the “Staff”) of the U.S. Securities and Exchange Commission (the “Commission”) relating to the Form 20-F for the year ended December 31, 2022 of Equinor ASA (the “Company”) (File Number 001-15200), following review of the Company’s response letter dated June 21, 2023 (the “Response”).

To facilitate the Staff’s review of our response, we have included in this letter the caption and comment from the Staff’s comment letter in bold text and have provided our response immediately following the comment.

Form 20-F for the Fiscal Year Ended December 31, 2022

Notes to the Consolidated Financial Statements, page 67

We note your response to prior comment one explaining that you believe the methods used to compute basic and diluted earnings per share were sufficiently disclosed because the amounts utilized are available in the Statement of Income, although you agree to include in future filings “...references to notes to the financial statements where applicable information relating to basic and diluted earnings per share” can be found.

We are unable to ascertain from your response whether you have agreed to disclose the calculations of basic and diluted earnings per share as required by paragraphs (a) and (b) of IAS 33.70. We believe that you should disclose within the notes to the financial statements the details that are prescribed by this standard.

Page 1 of 2

Equinor ASA

Office address

Telephone

www.equinor.com

Registered number

Forusbeen 50

+47 51990000

4035 Stavanger, Norway

Classification: confidential

Please confirm that you will provide disclosure consistent with the table included within your response regarding the calculations of basic and diluted earnings per share.

The Company confirms that, going forward, when it presents basic and diluted earnings per share in its annual financial statements filed with the Commission, it will also provide within the notes to such financial statements disclosure consistent with the table included within the Response regarding the calculations of those amounts.

***

If you have any questions relating to this letter, please call John Horsfield-Bradbury at +44 20 7959 8491. He may also be reached by e-mail at horsfieldbradburyj@sullcrom.com.

Very truly yours,
/s/ May-Kirsti Enger

Show Raw Text
CORRESP
1
filename1.htm

CORRESP

 July 11, 2023

 Via
EDGAR

 Mr. Joseph Klinko

 Staff Accountant, Office of
Energy & Transportation

 Division of Corporation Finance

U.S. Securities and Exchange Commission

 100 F Street, N.E.

Washington, DC 20549

 USA

Re: Equinor ASA

 Form
20-F for Fiscal Year Ended December 31, 2022

 Filed March 23, 2023

Response dated June 21, 2023

 File No. 001-15200

 Dear Mr. Klinko,

Thank you for your letter dated June 30, 2023, setting forth comments of the staff (the “Staff”) of the U.S. Securities
and Exchange Commission (the “Commission”) relating to the Form 20-F for the year ended December 31, 2022 of Equinor ASA (the “Company”) (File Number 001-15200), following review of the Company’s response letter dated June 21, 2023 (the “Response”).

To facilitate the Staff’s review of our response, we have included in this letter the caption and comment from the Staff’s comment
letter in bold text and have provided our response immediately following the comment.

 Form 20-F for the Fiscal
Year Ended December 31, 2022

 Notes to the Consolidated Financial Statements, page 67

We note your response to prior comment one explaining that you believe the methods used to compute basic and diluted earnings per share were sufficiently
disclosed because the amounts utilized are available in the Statement of Income, although you agree to include in future filings “...references to notes to the financial statements where applicable information relating to basic and diluted
earnings per share” can be found.

 We are unable to ascertain from your response whether you have agreed to disclose the calculations of basic
and diluted earnings per share as required by paragraphs (a) and (b) of IAS 33.70. We believe that you should disclose within the notes to the financial statements the details that are prescribed by this standard.

Page 1 of 2

Equinor ASA

Office address

Telephone

www.equinor.com

Registered number

Forusbeen 50

+47 51990000

923609016

4035 Stavanger, Norway

Classification: confidential

 Please confirm that you will provide disclosure consistent with the table included within your response
regarding the calculations of basic and diluted earnings per share.

 The Company confirms that, going forward, when it presents basic
and diluted earnings per share in its annual financial statements filed with the Commission, it will also provide within the notes to such financial statements disclosure consistent with the table included within the Response regarding the
calculations of those amounts.

 ***

If you have any questions relating to this letter, please call John Horsfield-Bradbury at +44 20 7959
8491. He may also be reached by e-mail at horsfieldbradburyj@sullcrom.com.

Very truly yours,

/s/ May-Kirsti Enger

May-Kirsti Enger

Senior Vice President, Group Accounting and Financial Compliance

cc:
 Anders Opedal

(Equinor ASA)

 Torgrim Reitan

 (Equinor ASA)

 John
Horsfield-Bradbury

 (Sullivan & Cromwell LLP)

Page 2 of 2

 Equinor ASA

Registered number

 923609016

 Office address

Forusbeen 50

 4035 Stavanger, Norway

 Telephone

+47 51990000

 www.equinor.com

: