United States securities and exchange commission logo
August 16, 2023
Xavier Destriau
Chief Financial Officer
ZIM Integrated Shipping Services Ltd.
9 Andrei Sakharov Street
Matam, Haifa 3190500
Israel
Re: ZIM Integrated
Shipping Services Ltd.
Form 20-F for the
Fiscal Year ended December 31, 2022
Filed March 13,
2023
File No. 001-39937
Dear Xavier Destriau:
We have limited our review of your filing to the financial
statements and related
disclosures and have the following comment. In some of our comments, we
may ask you to
provide us with information so we may better understand your disclosure.
Please respond to this comment 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 our
comment applies to your facts and circumstances, please tell us why in
your response.
After reviewing your
response to this comment, we may have additional comments.
Form 20-F for the Fiscal Year ended December 31, 2022
Financial Statements
Note 25 - Segment Information, page F-65
1. We note that you
present freight revenues disaggregated by geographic trade zones and
assess the performance
of each trade zone in terms of TCRs carried, average freight rate
per TEU carried, and
freight revenues from containerized cargo when discussing your
results of operations
in Item 5 of the Form 20-F.
We also note various
statements made by company representatives during the March 13,
2023 and May 22, 2023
earnings calls, describing several resource allocation decisions
that involved
consideration of your geographic trade zone metrics, rather than being
limited to consolidated
information, such as the switch of allocated tonnage between trade
lanes and the
introduction of a new line in response to significant rate erosion and
Xavier Destriau
ZIM Integrated Shipping Services Ltd.
August 16, 2023
Page 2
considering comparatively favorable opportunities for growth and profit.
Given your ability to correlate revenues with the geographic regions in
which your ships
are operating it is unclear why information about the costs and overall
economics of
operating those ships in those geographic regions would not be readily
available and
similarly associated with the same geographic regions.
Please explain to us why the five geographic regions would not be
considered reportable
operating segments, if this is your view, given the extent and nature of
the financial
information underlying the disclosures and commentary referenced above,
and
considering the guidance in IFRS 8, including paragraphs 5 and 8,
regarding the
availability of discrete financial information, and paragraphs 7 and 9,
concerning your
identification of the chief operating decision maker function.
If you do not believe that you have additional reportable operating
segments, please
include a comprehensive analysis of the guidance referenced above along
with your
response. Otherwise, please describe the incremental disclosures that you
propose to
address the requirements in paragraph 21 of IFRS 8.
In closing, 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.
You may contact Jenifer Gallagher, Staff Accountant at (202) 551-3706 or
John
Cannarella, Staff Accountant at (202) 551-3337 with questions regarding your
financial
statements and related disclosures.
You may contact Karl Hiller, Branch Chief at (202) 551-3686 with any
other questions.
Sincerely,
FirstName LastNameXavier Destriau
Division of
Corporation Finance
Comapany NameZIM Integrated Shipping Services Ltd.
Office of Energy &
Transportation
August 16, 2023 Page 2
cc: Michael Kaplan
FirstName LastName