SRSEC Reporting Desk

Clinuvel Pharmaceuticals Ltd (CUVL, CLVLF) – Company response

2026-06-15 · Re: · Accession 0001493152-26-028644 · Agreed to revise

Responds to staff letter of 2026-04-23.

IFRS & Foreign Private IssuersCapitalization, Equity & Escrow

2026-04-23 · · Comment 1 · 2024 (Unaudited and Presented on an IFRS basis), page F-24 Agreed to revise
Staff comment: As your June 30, 2025 annual audited financial statements are prepared in accordance with U.S. GAAP, all interim unaudited financial statements required in the registration statement must also be prepared under U.S. GAAP as required by Item 8.A.5 of Form 20-F. Note that while foreign private issuers are allowed to initially include more current published information, that published data accommodation does not waive the underlying requirement for consistent accounting standards in a registration statement. Please revise to disclose the following: • Revise to replace your current December 31, 2025 interim unaudited financial statement prepared under IFRS with financial statements prepared… letter →
Company response: In response to the Staff’s comments, we have revised our disclosures beginning on page F-24 of the Registration Statement to replace our current December 31, 2025 interim unaudited financial statement prepared under IFRS with financial statements prepared under U.S. GAAP and also revised other areas of the Registration Statement impacted by the change, including our capitalization table and Item 5. Operating and financial review and prospects. We appreciate the assistance the Staff has provided with its comments. response letter →
IFRS & Foreign Private IssuersCapitalization, Equity & Escrow

Full letter on EDGAR → · Filing index · All Clinuvel Pharmaceuticals Ltd (CUVL, CLVLF) correspondence

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