Correspondence 0001104659-23-010249 from QIWI (CIK 0001561566)
QIWI (CIK 0001561566)
Date: Feb. 3, 2023 · CIK: 0001561566 · Accession: 0001104659-23-010249
AI Filing Summary & Sentiment
File numbers found in text: 001-35893
Letter
QIWI PLC
12 Kennedy Avenue, Kennedy Business Centre, 2nd Floor, 1087-Nicosia, Cyprus
+357 22-65-33-90, fax +357 22-76-09-18, office@qiwi.com.cy, qiwi.com
February 3, 2023
VIA EDGAR
Division of Corporation Finance
Office of Trade & Services
U.S. Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
Attn:
Robert Shapiro
Lyn Shenk
Nicholas Nalbantian
Cara Wirth
RE: QIWI PLC
Form 20-F for Fiscal Year Ended December 31, 2021
Filed April 29, 2022
File No. 001-35893
Ladies and Gentlemen:
I am writing on behalf of QIWI PLC (“QIWI”, “Company” or “we”) in response to the comments of the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) set forth in the letter from the Division of Corporation Finance dated January 26, 2023 (the “Comment Letter”) with respect to the above-referenced Form 20-F for the fiscal year ended December 31, 2021 (the “Form 20-F”) as filed with the Commission on April 29, 2022.
This letter is being filed with the Commission electronically via the EDGAR system today. The headings and numbered paragraphs below correspond to the headings and numbered paragraphs set forth in the Comment Letter. For the Staff's convenience, we have set forth below each of the numbered comments of your letter in italics followed by QIWI’s responses thereto. Capitalized terms used but not defined in this letter have the meanings given to them in the Form 20-F.
Robert Shapiro
Lyn Shenk
Nicholas Nalbantian
Cara Wirth
January 26, 2023
Page 2
Response Dated January 26, 2023
Board of Directors, page 116
Comment 1:
We note your response to comment 10 and we reissue it. In future filings, please include the information that was provided in response to this comment regarding the types of reports that the board regularly receives and analyzes from management. Also, please specifically describe the extent and nature of the role of the board in overseeing risks related to Russia’s invasion of Ukraine, if any.
Company Response:
We respectfully note the Staff’s comment to our disclosure on page 116 of the Form 20-F and we confirm that in future filings we will include the types of reports that the board regularly receives and analyzes from QIWI’s management regarding various matters, including amongst others sanctions compliance, risk management status, cybersecurity statistics, employee matters, KPI updates and updates on other matters related to Company’s operations in the countries in which we operate.
* * * * *
We hope that the foregoing has been responsive to the Staff’s comments. If you have any questions or comments with respect to this matter, please contact the undersigned at +35725028091 or ir@qiwi.com.
Sincerely,
/s/ Alexey Mashchenkov
Show Raw Text
CORRESP
1
filename1.htm
QIWI PLC
12 Kennedy Avenue, Kennedy Business Centre, 2nd Floor, 1087-Nicosia, Cyprus
+357 22-65-33-90, fax +357 22-76-09-18, office@qiwi.com.cy, qiwi.com
February 3, 2023
VIA EDGAR
Division of Corporation Finance
Office of Trade & Services
U.S. Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
Attn:
Robert Shapiro
Lyn Shenk
Nicholas Nalbantian
Cara Wirth
RE:
QIWI PLC
Form 20-F for Fiscal Year Ended December
31, 2021
Filed April 29, 2022
File No. 001-35893
Ladies and Gentlemen:
I am writing on behalf of
QIWI PLC (“QIWI”, “Company” or “we”) in response to the comments of the staff (the “Staff”)
of the Securities and Exchange Commission (the “Commission”) set forth in the letter from the Division of Corporation
Finance dated January 26, 2023 (the “Comment Letter”) with respect to the above-referenced Form 20-F for the fiscal
year ended December 31, 2021 (the “Form 20-F”) as filed with the Commission on April 29, 2022.
This letter is being filed
with the Commission electronically via the EDGAR system today. The headings and numbered paragraphs below correspond to the headings and
numbered paragraphs set forth in the Comment Letter. For the Staff's convenience, we have set forth below each of the numbered comments
of your letter in italics followed by QIWI’s responses thereto. Capitalized terms used but not defined in this letter have the meanings
given to them in the Form 20-F.
Robert Shapiro
Lyn Shenk
Nicholas Nalbantian
Cara Wirth
January 26, 2023
Page 2
Response Dated January 26, 2023
Board of Directors, page 116
Comment 1:
We note your response to comment 10 and we reissue it. In future
filings, please include the information that was provided in response to this comment regarding the types of reports that the board regularly
receives and analyzes from management. Also, please specifically describe the extent and nature of the role of the board in overseeing
risks related to Russia’s invasion of Ukraine, if any.
Company Response:
We respectfully note the Staff’s comment to our disclosure on
page 116 of the Form 20-F and we confirm that in future filings we will include the types of reports that the board regularly receives
and analyzes from QIWI’s management regarding various matters, including amongst others sanctions compliance, risk management status,
cybersecurity statistics, employee matters, KPI updates and updates on other matters related to Company’s operations in the countries
in which we operate.
* * * * *
We hope that the foregoing
has been responsive to the Staff’s comments. If you have any questions or comments with respect to this matter, please contact
the undersigned at +35725028091 or ir@qiwi.com.
Sincerely,
/s/ Alexey Mashchenkov
Chief Financial Officer