SEC Comment Letter 0000000000-24-010663 to Polestar Automotive Holding UK PLC (PSNY, PLSAY, PSNYW) (CIK 0001884082) (PSNY)
Polestar Automotive Holding UK PLC (PSNY, PLSAY, PSNYW) (CIK 0001884082)
Date: Sept. 19, 2024 · CIK: 0001884082 · Accession: 0000000000-24-010663
AI Filing Summary & Sentiment
File numbers found in text: 001-41431
Letter
September 19, 2024 Per Ansgar Chief Financial Officer Polestar Automotive Holding UK PLC Assar Gabrielssons Väg 9 405 31 Gothenburg, Sweden Re:Polestar Automotive Holding UK PLC Form 20-F for the Fiscal Year Ended December 31, 2023 File No. 001-41431 Dear Per Ansgar: We have reviewed your filing and have the following comments. 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 20-F for the Fiscal Year Ended December 31, 2023 Item 6. Directors, Senior Management and Employees F. Disclosure of a registrant's action to recover erroneously awarded , page 56 1.We note that in 2023 your executive officers received bonuses based on the achievement of key performance indicators as determined by your board of directors. We also note your statement that there was no recovery of erroneously awarded compensation. Please briefly explain to us why application of the recovery policy resulted in this conclusion. See Item 402(w)(2) of Regulation S-K. 2.It appears that you have not provided your disclosure about your recovery analysis in an Interactive Data File in accordance with Rule 405 of Regulation S-T and the EDGAR Filer Manual. In future filings where you conduct a recovery analysis, please also include the interactive data. 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.
September 19, 2024 Page 2 Please contact Robert Arzonetti at 202-551-8819 or Sebastian Gomez Abero at 202-551- 3578 with any other questions. Sincerely, Division of Corporation Finance Office of Finance
Show Raw Text
September 19, 2024
Per Ansgar
Chief Financial Officer
Polestar Automotive Holding UK PLC
Assar Gabrielssons Väg 9
405 31 Gothenburg, Sweden
Re:Polestar Automotive Holding UK PLC
Form 20-F for the Fiscal Year Ended December 31, 2023
File No. 001-41431
Dear Per Ansgar:
We have reviewed your filing and have the following comments.
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 20-F for the Fiscal Year Ended December 31, 2023
Item 6. Directors, Senior Management and Employees
F. Disclosure of a registrant's action to recover erroneously awarded , page 56
1.We note that in 2023 your executive officers received bonuses based on the achievement
of key performance indicators as determined by your board of directors. We also note
your statement that there was no recovery of erroneously awarded compensation. Please
briefly explain to us why application of the recovery policy resulted in this conclusion.
See Item 402(w)(2) of Regulation S-K.
2.It appears that you have not provided your disclosure about your recovery analysis in an
Interactive Data File in accordance with Rule 405 of Regulation S-T and the EDGAR
Filer Manual. In future filings where you conduct a recovery analysis, please also include
the interactive data.
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.
September 19, 2024
Page 2
Please contact Robert Arzonetti at 202-551-8819 or Sebastian Gomez Abero at 202-551-
3578 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Finance