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UPLOAD Filing

Empro Group Inc.
Date: May 19, 2025 · CIK: 0002005569 · Accession: 0000000000-25-005317

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File numbers found in text: 333-282155

Date
May 19, 2025
Author
Division of
Form
UPLOAD
Company
Empro Group Inc.

Letter

Re: Empro Group Inc. Amendment No. 7 to Registration Statement on Form F-1 Filed May 9, 2025 File No. 333-282155 Dear Yeoh Chee Wei:

May 19, 2025

Yeoh Chee Wei Chief Executive Officer Empro Group Inc. 21, Jalan 15/23, Tiong Nam Industry Park, 40200 Shah Alam Selangor, Malaysia

We have reviewed your amended registration statement and have the following comments.

Please respond to this letter by amending your registration statement and providing the requested information. If you do not believe a comment applies to your facts and circumstances or do not believe an amendment is appropriate, please tell us why in your response.

After reviewing any amendment to your registration statement and the information you provide in response to this letter, we may have additional comments. Unless we note otherwise, any references to prior comments are to comments in our April 15, 2025 letter.

Amendment No. 7 to Registration Statement on Form F-1 filed May 9, 2025 Note 24, page F-50

1. We note your response to prior comment 5. Please explain to us how you concluded that Empro Group's issuance of 5,250,000 ordinary shares to the existing shareholders of Empro Group on a pro rata basis for a purchase price equal to $0.0001 per share is not a bonus issue and/or essentially a stock split. In this regard, we note that this issuance materially increased the number of shares outstanding without impacting the total value of your shares or the ownership of your stockholders. Please reassess the guidance in paragraph 64 of IAS 33 as well as SAB Topic 4:C and revise your financial statements as necessary. May 19, 2025 Page 2 Note 28, page F-55

2. Please expand this disclosure to report a measure of profit or loss for each of your two reportable segments. See paragraph 23 of IFRS 8. Any material variances in segment profit or loss should also be explained in MD&A.

Please contact Al Pavot at 202-551-3738 or Jeanne Baker at 202-551-3691 if you have questions regarding comments on the financial statements and related matters. Please contact Robert Augustin at 202-551-8483 or Katherine Bagley at 202-551-2545 with any other questions.

Sincerely,
Division of
Corporation Finance
Office of
Industrial Applications and
Services
cc: Michael T. Campoli

Show Raw Text
<DOCUMENT>
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<TEXT>
 May 19, 2025

Yeoh Chee Wei
Chief Executive Officer
Empro Group Inc.
21, Jalan 15/23, Tiong Nam Industry Park, 40200 Shah Alam
Selangor, Malaysia

 Re: Empro Group Inc.
 Amendment No. 7 to Registration Statement on Form F-1
 Filed May 9, 2025
 File No. 333-282155
Dear Yeoh Chee Wei:

 We have reviewed your amended registration statement and have the
following
comments.

 Please respond to this letter by amending your registration statement
and providing
the requested information. If you do not believe a comment applies to your
facts and
circumstances or do not believe an amendment is appropriate, please tell us why
in your
response.

 After reviewing any amendment to your registration statement and the
information
you provide in response to this letter, we may have additional comments. Unless
we note
otherwise, any references to prior comments are to comments in our April 15,
2025 letter.

Amendment No. 7 to Registration Statement on Form F-1 filed May 9, 2025
Note 24, page F-50

1. We note your response to prior comment 5. Please explain to us how you
concluded
 that Empro Group's issuance of 5,250,000 ordinary shares to the existing
shareholders
 of Empro Group on a pro rata basis for a purchase price equal to $0.0001
per share is
 not a bonus issue and/or essentially a stock split. In this regard, we
note that this
 issuance materially increased the number of shares outstanding without
impacting the
 total value of your shares or the ownership of your stockholders. Please
reassess the
 guidance in paragraph 64 of IAS 33 as well as SAB Topic 4:C and revise
your
 financial statements as necessary.
 May 19, 2025
Page 2
Note 28, page F-55

2. Please expand this disclosure to report a measure of profit or loss for
each of your two
 reportable segments. See paragraph 23 of IFRS 8. Any material variances
in segment
 profit or loss should also be explained in MD&A.

 Please contact Al Pavot at 202-551-3738 or Jeanne Baker at 202-551-3691
if you
have questions regarding comments on the financial statements and related
matters. Please
contact Robert Augustin at 202-551-8483 or Katherine Bagley at 202-551-2545
with any
other questions.

 Sincerely,

 Division of
Corporation Finance
 Office of
Industrial Applications and
 Services
cc: Michael T. Campoli
</TEXT>
</DOCUMENT>