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                              January 22, 2024

       Gisele Remy
       Chief Financial Officer
       Auna S.A.
       46 A, Avenue JF Kennedy
       1855 Luxembourg
       Grand Duchy of Luxembourg

                                                        Re: Auna S.A.
                                                            Registration
Statement on Form F-1
                                                            Filed January 9,
2024
                                                            File No. 333-276435

       Dear Gisele Remy:

                                                        We have reviewed your
registration statement and have the following comment(s).

              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 December 29,
2023 letter.

       Registration Statement on Form F-1 filed January 9, 2024

       Summary
       The Auna Way, page 1

   1.                                                   We note your response
to comment 4 and your revised disclosure on page v, which
                                                        generally describes the
basis for your belief that you provide "high-quality" care, services
                                                        and patient outcomes,
including "excellent" and "effective" patient outcomes. Please
                                                        revise your filing to
discuss specifically how you measure "quality," including with
                                                        respect to care,
services, and patient outcomes. As a related matter, where you note that
                                                        you achieve "excellent"
and "effective" patient outcomes, please clarify how you define
                                                        each of these terms,
and how you measure outcomes. Please reference the specific metrics
                                                        on which you rely, such
as, for example, complication rates, mortality rates and patient
                                                        satisfaction rates and
discuss how your scores in these areas compare to your peers.
 Gisele Remy
FirstName
Auna S.A. LastNameGisele Remy
Comapany
January 22,NameAuna
           2024      S.A.
January
Page 2 22, 2024 Page 2
FirstName LastName
Unaudited Preliminary Results for the Year Ended December 31, 2023, page 19

2.       We note your disclosure that "[t]hese estimates should not be relied
upon as fact or as an
         accurate representation of future results." Please revise the
disclosure in this section to
         remove any implication that investors should not rely on the
information presented. If you
         choose to disclose preliminary results, you should be able to assert
that the actual results
         are not expected to differ materially from that reflected in the
preliminary results.
Acquisition of Partial Minority Interest in IMAT Oncom  dica, page 20

3.       We note your revised disclosure here that in connection with your
acquisition of 70% of
         the shares of IMAT Oncom  dica, you agreed to a put/call option
relating to 18% of one of
         the sellers    remaining interest in IMAT Oncom  dica, along with
certain earn-out
         obligations. Please revise your disclosure here to discuss in greater
detail the put/call
         option, including any material terms related to that option, and the
earn-out obligations.
The Offering, page 27

4.       We note your disclosure here and throughout the prospectus discussing
your directed
         share program. Please revise your risk factors to discuss that the
disclosure in your
         prospectus, including your beneficial ownership table on page 176,
assumes that no class
         A shares are purchased pursuant to the directed share program and the
risks related to this
         program, including that your directors, officers, employees and other
affiliates may
         participate in this program resulting in further concentration of
beneficial ownership and
         control than is reflected in this prospectus. Additionally, where you
discuss the directed
         share program, please expand your disclosure to address the process
that prospective
         participants will follow to participate in the program, the manner in
which you will
         communicate with participants and determine the amount each will
receive, when and
         how you will determine the allocation for the program, and whether
such allocation will
         change depending on the interest level of potential participants, as
well as any other
         material features of the program.
Use of Proceeds, page 63

5.       We note your revised disclosure that "our shareholders are required
under the terms of the
         Sponsor Financing to repay the Sponsor Financing with proceeds they
receive from an
         equity offering by us," and that, "[t]o facilitate that repayment, we
will acquire Heredia
         Investments by way of a merger of Heredia Investments into Auna Salud.
As a
         consequence of the merger, Auna Salud will assume the Sponsor
Financing and, in turn,
         Auna will use the proceeds from this offering to repay all amounts
outstanding under the
         Sponsor Financing." Please revise your disclosure related to this
merger and the
         repayment of the Sponsor Financing to address the following:

                Based on your disclosure that, pursuant to the terms of the
Sponsor Financing, you
              are obligated to provide proceeds from an equity offering to the
relevant shareholders
 Gisele Remy
FirstName
Auna S.A. LastNameGisele Remy
Comapany
January 22,NameAuna
           2024      S.A.
January
Page 3 22, 2024 Page 3
FirstName LastName
              to repay the financing, and your disclosure that in connection
with the merger with
              Heredia, you will assume the Sponsor Financing, please revise
your disclosure here
              to provide the information required by Item 3.C.4. of Form 20-F
with respect to this
              indebtedness. Please also file the documents governing the
Sponsor Financing as
              exhibits to your registration statement or tell us why you
believe you are not required
              to do so. See Item 601(b)(10) of Regulation S-K.

                Please advise whether you have entered into, or plan to enter
into, any agreement(s)
              with respect to your merger with Heredia Investments. If so,
please revise your
              disclosure in the Related Party Transactions section or in
another appropriate section
              of your prospectus to discuss the material terms of any relevant
agreement(s). Please
              also file any agreements as exhibits to your registration
statement. See Item
              601(b)(10) of Regulation S-K.

                We note that as a result of the merger, you will assume the
Sponsor Financing. Given
              that you are anticipated to assume this liability, please revise
your disclosure on page
              184 to disclose all material terms of the agreement including the
outstanding
              principal, the interest rate, any restrictive covenants, other
obligations and events of
              default. Please also revise your risk factors accordingly.
Management's Discussion and Analysis of Financial Condition and Results of
Operations
Contractual Obligations and Commitments
Senior Secured Notes Due 2029, page 90

6.       We note your revised disclosure in response to comment 11. Please
revise to describe the
         terms of your 2029 Notes and other debt instruments, including
financial covenants,
         ratios, and any significant restrictions on your ability to make
investments or raise
         additional capital. For example, provide an expanded description here
and in your risk
         factor on page 48 of the various restrictions imposed by the indenture
governing your
         2029 Notes, including restrictions on your ability to make investments
and enter
         transactions with affiliates and make strategic acquisitions or
exploit business
         opportunities. Ensure to provide quantified disclosure of the
financial covenants and
         ratios.
Underwriting
Other Relationships, page 219

7.       We note your disclosure here that certain of the underwriters and/or
their respective
         affiliates are lenders and/or agents under the Credit Agreement and
the Sponsor
         Financing. We also note your revised disclosure in the Use of Proceeds
on page 65 that
         proceeds from this offering will be used to repay the Sponsor
Financing and the term
         loans. Please revise your disclosure to clarify which underwriters
and/or their affiliates
         will receive a portion of the net proceeds. Additionally, please tell
us whether you are
         required to have a qualified independent underwriter in accordance
with FINRA Rule
 Gisele Remy
FirstName
Auna S.A. LastNameGisele Remy
Comapany
January 22,NameAuna
           2024      S.A.
January
Page 4 22, 2024 Page 4
FirstName LastName
         5121.
Condensed Consolidated Interim Financial Statements
4. Trade Accounts Receivable, page F-13

8.       We have reviewed your response to prior comment 15 and note that
220,411,000 soles is
         pending collection mainly due to the process with the third-party
insurance and
         institutional providers and that you also have not identified any
impairment indicators. We
         further note the detailed process which can cause a lengthening of the
time it takes to
         collect accounts receivable and that your accounts receivable for
payments from the third-
         party insurance and institutional providers are typically collected on
an average of 41 days
         in Mexico, 114 days in Peru and 149 days in Colombia. We note,
however, that certain of
         your June 30, 2023 accounts receivable are at least 283 days past due,
373 days past due,
         and 552 days past due, as of January 8, 2024, significantly greater
than your average
         collection periods. We also note your 2023 loss for impairment of
trade receivables of
         3,383,000 soles is not significant relative to 2023 total revenue and
trade accounts
         receivable as of September 30, 2023. Please clarify for us with
greater specificity the
         recent procedures you have undertaken to evaluate the collectability
of accounts
         receivable that were past due by more than 283 days and how you
determined that there
         are no impairment indicators. In addition, please clarify for us the
extent to which you
         consider the length of time an account has been past due to be an
indicator of impairment
         and describe to us your recent history for collecting accounts that
are significantly past
         due.
Exhibits

9.       We note that you have removed the placeholder from your exhibit index
for the "Opinion
         of Davis Polk & Wardwell LLP, U.S. counsel to Auna S.A., regarding
certain U.S. tax
         matters." However, you disclose on page 207 that "[t]he following
section is the opinion
         of Davis Polk & Wardwell LLP of the material U.S. federal income tax
consequences to
         U.S. Holders." Please file the short- or long-form opinion of Davis
Polk & Wardwell LLP
         as an exhibit to your registration statement. See Section III.B. of
Staff Legal Bulletin 19,
         available on our public website.
10.      We note the assumptions in paragraph 3 of exhibit 5.1, including:
"that the issuance of the
         Shares will be made out of the authorized share capital pursuant to
resolutions to be taken
         by the board of directors of the Company on or about the date of
issuance of the shares
         (the Share Capital Increase) conditional to the Shares being fully
paid-up." The staff
         considers it inappropriate for counsel to include in its opinion
assumptions that are overly
         broad, that "assume away" the relevant issue, or that assume any of
the material facts
         underlying the opinion or any readily ascertainable facts. In this
regard, please have
         counsel revise or remove the statement noted above so that the opinion
does not "assume
         away" any of the material facts underlying the opinion or any readily
ascertainable facts.
         See Section II.B.3.a. of Staff Legal Bulletin 19.
 Gisele Remy
Auna S.A.
January 22, 2024
Page 5

        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.

       Refer to Rules 460 and 461 regarding requests for acceleration. Please
allow adequate
time for us to review any amendment prior to the requested effective date of
the registration
statement.

       Please contact Christie Wong at 202-551-3684 or Michael Fay at
202-551-3812 if you
have questions regarding comments on the financial statements and related
matters. Please
contact Jessica Ansart at 202-551-4511 or Katherine Bagley at 202-551-2545 with
any other
questions.



                                                           Sincerely,

FirstName LastNameGisele Remy                              Division of
Corporation Finance
                                                           Office of Industrial
Applications and
Comapany NameAuna S.A.
                                                           Services
January 22, 2024 Page 5
cc:       Maurice Blanco
FirstName LastName