Spin-off - NOVARTIS AG

Form Type: CORRESP

Filing Date: 2025-03-31

Corporate Action: Spin-off

Type: Update

Accession Number: 000110465925029912

Filing Summary: Novartis AG responds to the SEC's comment letter dated March 18, 2025, regarding their Annual Report on Form 20-F for the fiscal year ending December 31, 2024, filed on January 31, 2025. The letter details how, following the spin-off of the Sandoz business on October 3, 2023, Novartis now operates solely as a single global segment innovative medicines company. This decision was made based on the IFRS 8 principles, as the company no longer has separate operating segments. The structure is explained, highlighting the integration of all activities related to innovative medicines and the role of the Executive Committee Nova (ECN) in resource allocation and performance assessment. Future filings will expand on risk factor disclosures regarding the upcoming patent expirations of Entresto, which currently generates significant sales revenue.