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CORRESP
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CORRESP

 Maurice Blanco

 maurice.blanco@davispolk.com

 Davis Polk & Wardwell LLP

450 Lexington Avenue
New York, NY 10017

 January 25, 2024

Re:
 Auna S.A.

Registration Statement on Form F-1

Filed January 9, 2024

 File No. 333-276435

 U.S. Securities and Exchange Commission

Division of Corporation Finance

 Office of Industrial
Applications and Services

 100 F Street, N.E.

 Washington,
D.C. 20549

Attn:
 Jessica Ansart

Katherine Bagley

 Dear Ms. Ansart and
Ms. Bagley:

 On behalf of our client, Auna S.A. (the “Company”), we are responding to the comments from the Staff (the
“Staff”) of the Securities and Exchange Commission (the “Commission”) relating to the Company’s Registration Statement on Form F-1 (the “Registration
Statement”) contained in the Staff’s letter dated January 22, 2024 (the “Comment Letter”). In response to the comments set forth in the Comment Letter, the Company has revised the Registration Statement and is
publicly filing it as amendment no. 1 to the Registration Statement and together with this response letter. The revised Registration Statement also contains certain additional updates and revisions.

Set forth below are the Company’s responses to the Staff’s comments. For convenience, the Staff’s comments are repeated below in italics,
followed by the Company’s response to the comments as well as a summary of the responsive actions taken. We have included page numbers to refer to the location in the revised Registration Statement where the revised language addressing a
particular comment appears.

 In addition, the revised Registration Statement reflects responses to the comments conveyed orally by the Staff to us via
telephonic conversation on (x) January 17, 2024, including (i) revisions to the calculation of dilution to exclude all intangibles, (ii) inclusion of earnings per share calculated on a pro forma basis to give effect to the
Company’s reverse stock split expected to occur immediately prior to the offering and (iii) inclusion of an earnings per share note to the Company’s interim financial statements for the nine-month periods ended September 30, 2023
and 2022, and (y) on January 23, 2024, including inclusion of a footnote to the Company’s tabular presentation of healthcare service operational metrics to disclose the impact of COVID-19 during
2021 and a portion of the nine-month period ended September 30, 2022.

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January 25, 2024

 Finally, as discussed with the Staff via telephone, we respectfully note that the Company is hoping, subject
to market conditions, to commence its roadshow by January 31 and become effective on or about February 7. We greatly appreciate the Staff’s assistance in light of this timing.

Registration Statement on Form F-1 filed January 9, 2024

Summary

 The Auna Way, page 1

1.
 We note your response to comment 4 and your revised disclosure on page v, which generally describes the
basis for your belief that you provide “high-quality” care, services and patient outcomes, including “excellent” and “effective” patient outcomes. Please revise your filing to discuss specifically how you measure
“quality,” including with respect to care, services, and patient outcomes. As a related matter, where you note that you achieve “excellent” and “effective” patient outcomes, please clarify how you define each of these
terms, and how you measure outcomes. Please reference the specific metrics on which you rely, such as, for example, complication rates, mortality rates and patient satisfaction rates and discuss how your scores in these areas compare to your
peers.

 Response: In response to the Staff’s comment, the Company has revised the disclosure on pages 1, 2, 3, 10, 11,
12, 13, 14, 15, 18, 21, 37, 40, 41, 42, 76, 77, 79, 135, 136, 137, 146, 151, 152, 153, 154, 155, 156, 159 and 162 of the revised Registration Statement to delete the references to “high-quality” care, services and patient outcomes,
including “excellent” and “effective” patient outcomes.

 Unaudited Preliminary Results for the Year Ended December 31,
2023, page 19

2.
 We note your disclosure that “[t]hese estimates should not be relied upon
as fact or as an accurate representation of future results.” Please revise the disclosure in this section to remove any implication that investors should not rely on the information presented. If you choose to
disclose preliminary results, you should be able to assert that the actual results are not expected to differ materially from that reflected in the preliminary results.

Response: In response to the Staff’s comment, the Company has revised the disclosure on pages 19 and 20 of the revised Registration Statement to
remove any implication that investors should not rely on the information presented and to state that its actual financial results and financial position are not expected to differ materially from that reflected in the preliminary financial
information.

 Acquisition of Partial Minority Interest in IMAT Oncomédica, page 20

3.
 We note your revised disclosure here that in connection with your acquisition of 70% of the shares of IMAT
Oncomédica, you agreed to a put/call option relating to 18% of one of the sellers’ remaining interest in IMAT Oncomédica, along with certain earn-out obligations. Please revise your
disclosure here to discuss in greater detail the put/call option, including any material terms related to that option, and the earn-out obligations.

Response: In response to the Staff’s comment, the Company has revised the disclosure on page 21 of the revised Registration Statement to describe
in greater detail the put/call option, including the material terms related to that option, and the earn-out obligations.

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Commission

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January 25, 2024

 The Offering, page 27

4.
 We note your disclosure here and throughout the prospectus discussing your directed share program. Please
revise your risk factors to discuss that the disclosure in your prospectus, including your beneficial ownership table on page 176, assumes that no class A shares are purchased pursuant to the directed share program and the risks related to this
program, including that your directors, officers, employees and other affiliates may participate in this program resulting in further concentration of beneficial ownership and control than is reflected in this prospectus. Additionally, where you
discuss the directed share program, please expand your disclosure to address the process that prospective participants will follow to participate in the program, the manner in which you will communicate with participants and determine the amount
each will receive, when and how you will determine the allocation for the program, and whether such allocation will change depending on the interest level of potential participants, as well as any other material features of the program.

 Response: In response to the Staff’s comment, the Company has revised the disclosure on page 62 of the revised Registration
Statement under the heading “Following the completion of the offering, Enfoca, our controlling shareholder, will own approximately    % of our class B shares and    % of our class A shares and
certain of our officers and a majority of our directors may be employed by or otherwise affiliated with Enfoca, which could give rise to potential conflicts of interest with them and certain of our other shareholders,” to clarify that the
amounts held by Enfoca and Mr. Pinillos Casabonne assume no acquisition of class A shares pursuant to the Directed Share Program.

 The Company
respectfully advises the Staff that while the Company expects to allocate up to 5% of the class A shares sold in the offering to the Directed Share Program, the Company does not expect that participation by its directors and officers to meaningfully
concentrate beneficial ownership in the hands of such directors and officers given the significant ownership of Enfoca and Mr. Pinillos Casabonne and the dual-class structure of the Company’s shares.

In addition, the Company has revised the disclosure on page 63 of the revised Registration Statement under the headings “You may not be able to sell
class A shares you own at the time or the price you desire because an active or liquid market for these securities may not develop” and “Substantial sales of class A shares after this offering could cause the price of our class A shares to
decrease” to disclose the potential impacts of the Directed Share Program on the price and liquidity of the class A shares.

 The Company respectfully
advises the Staff that the mechanics of the Directed Share Program will follow standard market practice and that the disclosure on pages 27, 191 and 219 of the revised Registration Statement has been revised to provide that the Directed Share
Program will be administered by an affiliate of Morgan Stanley (the “DSP Administrator”) and to describe material features of the Directed Share Program, including the process related thereto.

To date, the Company has not provided any materials to potential investors in the Directed Share Program. After filing of the preliminary prospectus with the
Commission and launch of the initial public offering, the Company intends to send an e-mail communication regarding the Directed Share Program to certain directors, executive officers, consultants, employees
and other individuals associated with the Company. The communication will provide basic information about the Directed Share Program, including a clear statement that there is no obligation to participate in the Directed Share Program and buy class
A shares. The Company will provide a list of these potential

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January 25, 2024

participants to the DSP Administrator. The DSP Administrator will then contact these potential participants by e-mail with instructions on how to access a
secure website operated by the DSP Administrator, which will outline the procedures for participating in the Directed Share Program. Participants may only participate through an account custodied with the DSP Administrator (either an existing or new
account).

 After a subscription period, during which potential participants indicate how many class A shares they would like to purchase, the Company will
allocate class A shares among participants. The allocation will be at the Company’s sole discretion and will remain within the size reserved for the Directed Share Program as disclosed in the preliminary prospectus. On the evening of pricing,
each participant will be prompted to return to the secure website operated by the DSP Administrator to confirm the class A shares allocated to them at the initial public offering price; it is up to each participant whether to purchase any, all or
any portion of the class A shares allocated to them. Once allocations are confirmed, participants must deliver payment to the DSP Administrator for the applicable number of class A shares.

Communications from the Company and the DSP Administrator regarding the Directed Share Program will comply with Rule 134 of the U.S. Securities Act of 1933,
including the appropriate legends.

 Use of Proceeds, page 65

5.
 We note your revised disclosure that “our shareholders are required under the terms of the Sponsor
Financing to repay the Sponsor Financing with proceeds they receive from an equity offering by us,” and that, “[t]o facilitate that repayment, we will acquire Heredia Investments by way of a merger of Heredia Investments into Auna Salud.
As a consequence of the merger, Auna Salud will assume the Sponsor Financing and, in turn, Auna will use the proceeds from this offering to repay all amounts outstanding under the Sponsor Financing.” Please revise your disclosure related to
this merger and the repayment of the Sponsor Financing to address the following:

•

 Based on your disclosure that, pursuant to the terms of the Sponsor Financing, you are obligated to provide
proceeds from an equity offering to the relevant shareholders to repay the financing, and your disclosure that in connection with the merger with Heredia, you will assume the Sponsor Financing, please revise your disclosure here to provide the
information required by Item 3.C.4. of Form 20-F with respect to this indebtedness. Please also file the documents governing the Sponsor Financing as exhibits to your registration statement or tell us why you
believe you are not required to do so. See Item 601(b)(10) of Regulation S-K.

Response: In response to the Staff’s comment, the Company has revised the disclosure on page 68 of the revised Registration Statement to specify
that the Company is not a party to the Sponsor Financing and its shareholders are required under the terms of the Sponsor Financing to repay the Sponsor Financing with proceeds they receive from an equity offering by the Company (through a dividend
or loan from the proceeds of that offering, or through a secondary sale of shares in the Company by its shareholders). Moreover, the Company has revised the disclosure on page 68 of the revised Registration Statement to specify that on the closing
date of the offering, the Company will use the proceeds from the offering to loan funds to Heredia Investments, who will in turn use those funds to repay all amounts outstanding under the Sponsor Financing and as a result thereof, the

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documents governing the Sponsor Financing will be terminated. The Company respectfully advises the Staff that it has concluded that it is not required to file the documents governing the Sponsor
Financing as exhibits to its Registration Statement pursuant to Item 601(b)(10) of Regulation S-K as the Company is not, and will not become, a party to such agreements.

•

 Please advise whether you have entered into, or plan to enter into, any agreement(s) with respect to your
merger with Heredia Investments. If so, please revise your disclosure in the Related Party Transactions section or in another appropriate section of your prospectus to discuss the material terms of any relevant agreement(s). Please also file any
agreements as exhibits to your registration statement. See Item 601(b)(10) of Regulation S-K.

Response: The Company respectfully advises the Staff that it has revised the disclosure on page 68 of the revised Registration Statement to specify
that immediately after the Sponsor Financing is repaid in full and the documents governing the Sponsor Financing are terminated, the Company will acquire Heredia Investments by way of a merger of Heredia Investments into Auna Salud S.A.C. pursuant
to a merger agreement (the “Heredia Merger Agreement”). In connection therewith, the Company has revised the disclosure on page 191 of the revised Registration Statement to discuss the material terms of the Heredia Merger Agreement and has
filed a form of the Heredia Merger Agreement as Exhibit 10.33 to the revised Registration Statement.

•

 We note that as a result of the merger, you will assume the Sponsor Financing. Given that you are anticipated
to assume this liability, please revise your disclosure on page 184 to disclose all material terms of the agreement including the outstanding principal, the interest rate, any restrictive covenants, other obligations and events of default. Please
also revise your risk factors accordingly.

 Response: The Company respectfully advises the Staff that it has revised the
disclosure on page 68 of the revised Registration Statement to specify that on the closing date of the offering, the Company will use the proceeds from the offering to loan funds to Heredia Investments pursuant to a loan agreement (the “Heredia
Loan Agreement”). Heredia Investments will in turn use those funds to repay all amounts outstanding under the Sponsor Financing and as a result thereof, the documents governing the Spo