Securities and Exchange Commission
December 15, 2022
Page
4
Cost of sales, page 47
| 2. |
You state the decrease in the cost per session was due to maintenance costs being divided over a larger
number of chargers and sessions. Your accounting policy for cost of sales of charging sessions does not refer to maintenance costs. Please explain to us and disclose as appropriate the maintenance costs associated with charging sessions and revise
your accounting policy disclosure as appropriate. |
Response:
The Company respectfully acknowledges the Staff’s comment and notes that maintenance costs included in cost of sales associated with charging sessions
were less than € 1 million for each of the years ending December 31, 2020 and 2021, and were deemed immaterial for inclusion in the cost of sales accounting policy. However, the Company confirms that it will clarify its
accounting policy disclosures for cost of sales in its future filings, including its Annual Report on Form 20-F for the year ending December 31, 2022. For illustrative purposes, see response to question 4
below for the revised disclosure.
Notes to Consolidated Financial Statements
Note 2.7 Summary of Significant Accounting Policies
Note 2.7.3 Cost of sales, page F-21
| 3. |
It appears charging equipment and charging infrastructure you own are integral to the generation of charging
session revenue. Please explain to us your rationale for not including depreciation of these in cost of sales of charging sessions. |
Response: The Company respectfully acknowledges the Staff’s comment. The Company considered guidance in IAS 1, Presentation of Financial
Statements, in its presentation of the statement of profit or loss. IAS 1.99 requires the presentation of an analysis of expenses recognized in the statement of profit and loss using a classification based on either their nature or function
within the entity, whichever provides information that is reliable and more relevant. IFRS does not prescribe the components of cost of sales and the allocation of expenses by function is based on management’s judgment. The Company classifies
depreciation expenses within general and administrative expenses. Cost of sales is labeled as excluding depreciation.
Based on management’s
judgment, this presentation is more representative of how it viewed and managed the business and is in line with industry practice and peers in Europe.
During 2022, management has continued to evaluate the Company’s business model following its public listing through a business combination with Spartan
Acquisition Corp. III (the “Business Combination”). Using the proceeds from the Business Combination, management continues to invest in a more asset-intensive business model (e.g., the acquisition of
Mega-E) and therefore depreciation expense is more clearly linked to cost of sales. Based on this evaluation, the Company expects to adopt a voluntary change to its accounting policy for the allocation and
classification of depreciation expense to cost of sales and general and administrative expenses, effective December 31, 2022 applying the change retrospectively. Thereafter, the Company expects to allocate the depreciation expenses related to
its charging equipment and charging infrastructure to cost of sales of charging sessions. The Company believes that this will result in a more relevant and reliable classification as it is better aligned with the IFRS conceptual framework and more
consistent with our peer group, especially those in the United States.
Management will disclose any such change to its accounting policy in its Annual
Report on Form 20-F for the year ending December 31, 2022.
