TEXT-EXTRACT 2 filename2.txt United States securities and exchange commission logo December 4, 2020 Eli Glickman Chief Executive Officer and President ZIM Integrated Shipping Services Ltd. 9 Andrei Sakharov Street Matam Scientific Industries Center, P.O. Box 1723 Haifa 3101601, Israel Re: ZIM Integrated Shipping Services Ltd. Amendment No. 1 to Draft Registration Statement on Form F-1 Submitted November 20, 2020 CIK 0001654126 Dear Mr. Glickman: We have reviewed your amended draft registration statement and have the following comments. 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 letter by providing the requested information and either submitting an amended draft registration statement or publicly filing your registration statement on EDGAR. If you do not believe our comments apply to your facts and circumstances or do not believe an amendment is appropriate, please tell us why in your response. After reviewing the information you provide in response to these comments and your amended draft registration statement or filed registration statement, we may have additional comments. Amendment No. 1 to Draft Registration Statement on Form F-1 Management's Discussion and Analysis of Financial Condition and Results and Operations Critical accounting policies and estimates Impairment, page 73 1. We reviewed your response to our comment 6, that the Company's management considers historical utilization, amongst other factors, when forecasting its future operations. You also disclose in your risk factors that until excess capacity is fully absorbed in the shipping lines on which your operations are focused, the industry will continue to experience downward pressure on freight rates and such prolonged pressure could have a material adverse effect on your financial condition, results of operations and liquidity. Please tell Eli Glickman ZIM Integrated Shipping Services Ltd. December 4, 2020 Page 2 us whether you consider utilization rates to be key assumptions in calculating value-in-use and, if so, what consideration you gave to describing historical and projected future utilization rates as key assumptions in your assessment of impairment. You may contact Yolanda Guobadia, Staff Accountant, at 202-551-3562 or Gus Rodriguez, Accounting Branch Chief, at 202-551-3752 if you have questions regarding comments on the financial statements and related matters. Please contact Irene Barberena- Meissner, Staff Attorney, at 202-551-6548 or Loan Lauren Nguyen, Legal Branch Chief, at 202- 551-3642 with any other questions. Sincerely, FirstName LastNameEli Glickman Division of Corporation Finance Comapany NameZIM Integrated Shipping Services Ltd. Office of Energy & Transportation December 4, 2020 Page 2 cc: Pedro J. Bermeo, Esq. FirstName LastName