SEC Comment Letter 0000000000-24-009419 to Grifols SA (GRFS, GIFLF, GIFOF, GIKLY) (CIK 0001438569) (GRFS)
Grifols SA (GRFS, GIFLF, GIFOF, GIKLY) (CIK 0001438569)
Date: Aug. 16, 2024 · CIK: 0001438569 · Accession: 0000000000-24-009419
AI Filing Summary & Sentiment
File numbers found in text: 001-35193
Letter
August 16, 2024 David Bell General Counsel Grifols S.A. Avinguda de la Generalitat, 152-158 Parc de Negocis Can Sant Joan Sant Cugat del Valles 08174 Barcelona, Spain Re:Grifols S.A. Form 20-F for the fiscal year ended December 31, 2023 Filed April 19, 2024 Form 6-K filed July 30, 2024 File No. 001-35193 Dear David Bell: We have limited our review of your filings to the financial statements and related disclosures and have the following comment. Please respond to this letter within ten business days by providing the requested information or advise us as soon as possible when you will respond. If you do not believe a comment applies to your facts and circumstances, please tell us why in your response. After reviewing your response to this letter, we may have additional comments. Form 6-K filed July 30, 2024 Notes to the Condensed Consolidated Interim Financial Statements for the six-month period ended 30 June 2024 (2) Basis of Presentation and Accounting Principles Applied (d) Changes in accounting criteria and correction of errors Shanghai RAAS, page 4 Please provide an accounting analysis supporting your correction of prior financial reporting for the SRAAS investment and GDS non-controlling interest. Refer us to the technical guidance upon which your relied. In addition, provide the following information. Describe and quantify the methods and key assumptions used to calculate the restatement adjustment of €457.2 million and explain the relationship between •1.
August 16, 2024 Page 2 this amount and the SRAAS investment and GDS non-controlling interest as of March 30, 2020 and January 1, 2023. •Explain why this restatement had no effect on operating results reported for the SRAAS investment and GDS non-controlling interest from 2020 through 2023. •Clarify whether this accounting error was identified by management or Deloitte in connection with its review of your interim financial statements for the six months ended June 30, 2024. •Describe your "accounting policy adopted in March 2020 " that governed reciprocal interests held by GDS and SRAAS, explain its deficiencies and describe how they were corrected in this restatement. •Describe your current accounting policy for a "non-controlling interest when an investment in an associate has a stake in a Group company." In closing, we remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff. Please contact Frank Wyman at 202-551-3660 or Daniel Gordon at 202-551-3486 with any questions. Sincerely, Division of Corporation Finance Office of Life Sciences
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August 16, 2024
David Bell
General Counsel
Grifols S.A.
Avinguda de la Generalitat, 152-158
Parc de Negocis Can Sant Joan
Sant Cugat del Valles 08174
Barcelona, Spain
Re:Grifols S.A.
Form 20-F for the fiscal year ended December 31, 2023
Filed April 19, 2024
Form 6-K filed July 30, 2024
File No. 001-35193
Dear David Bell:
We have limited our review of your filings to the financial statements and related
disclosures and have the following comment.
Please respond to this letter within ten business days by providing the requested
information or advise us as soon as possible when you will respond. If you do not believe a
comment applies to your facts and circumstances, please tell us why in your response.
After reviewing your response to this letter, we may have additional comments.
Form 6-K filed July 30, 2024
Notes to the Condensed Consolidated Interim Financial Statements for the six-month period
ended 30 June 2024
(2) Basis of Presentation and Accounting Principles Applied
(d) Changes in accounting criteria and correction of errors
Shanghai RAAS, page 4
Please provide an accounting analysis supporting your correction of prior financial
reporting for the SRAAS investment and GDS non-controlling interest. Refer us to the
technical guidance upon which your relied. In addition, provide the following
information.
Describe and quantify the methods and key assumptions used to calculate the
restatement adjustment of €457.2 million and explain the relationship between •1.
August 16, 2024
Page 2
this amount and the SRAAS investment and GDS non-controlling interest as of
March 30, 2020 and January 1, 2023.
•Explain why this restatement had no effect on operating results reported for the
SRAAS investment and GDS non-controlling interest from 2020 through 2023.
•Clarify whether this accounting error was identified by management or Deloitte in
connection with its review of your interim financial statements for the six months
ended June 30, 2024.
•Describe your "accounting policy adopted in March 2020 " that governed reciprocal
interests held by GDS and SRAAS, explain its deficiencies and describe how they
were corrected in this restatement.
•Describe your current accounting policy for a "non-controlling interest when an
investment in an associate has a stake in a Group company."
In closing, we remind you that the company and its management are responsible for the
accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or
absence of action by the staff.
Please contact Frank Wyman at 202-551-3660 or Daniel Gordon at 202-551-3486 with
any questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences