United States securities and exchange commission logo

                              March 11, 2021

       Christian Hanke
       Chief Financial Officer
       Havre Global AB
       Stora Varvsgatan 6a
       211 19 Malm

                                                        Re: Havre Global AB
                                                            Confidential Draft
Registration Statement on Form F-1
                                                            Submitted February
12, 2021
                                                            CIK No. 0001843586

       Dear Mr. Hanke:

              We have reviewed your 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

             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

       Confidential Draft Registration Statement on Form F-1 submitted February
12, 2021

       Dilution, page 64

   1.                                                   Please revise to
disclose how the numbers and percentages in the table on page 65 would
                                                        change assuming the
exercise of all outstanding warrants.
       Expand global production capacity, page 72

   2.                                                   Please disclose the
source of funds you are using and intend to use to complete the
                                                        production capacity
expansion referenced in your disclosure, the amounts you have
                                                        already paid and the
amounts remaining to be paid. Also revise the disclosure in the first
                                                        two paragraphs on page
79, as appropriate, to reflect the obligations that you have and will
 Christian Hanke
Havre Global AB
March 11, 2021
Page 2
         have as a result of the planned expansion.
Driving the global appetite . . ., page 86

3.       Please clarify what you mean by the "highest amount of value growth"
and "value share,"
         as those terms are used in the first two bullets of this section.
4.       Please revise the last full paragraph on page 87 to clarify how
"continued investment in
         production, brand awareness, new markets and product development"
resulted in the
         margins and losses to which you refer.
Supply Chain Operations, page 104

5.       We note your disclosure on page 22 that as of December 31, 2020 you
had three suppliers
         for the oats used in your products. Please disclose whether you have
agreements with
         your suppliers. Please describe the terms of any such agreements.
Principal and Selling Shareholders, page 118

6.       For each entity listed in the table, please identify the natural
persons who have or share
         voting and/or dispositive power or the right to receive the economic
benefit of the
         securities. Please also tell us why China Resources Verlinvest Health
Investment Ltd. is
         not included in the table, given your disclosure on page F-41 that it
is the "controlling
         party" and owns 100% of the shares of Nativus Company Limited.
Additional Listing Agreement, page 119

7.       Please revise to clarify whether "[y]our shareholders or their
affiliates [are] owned or
         controlled by, or otherwise affiliated with, a foreign state,
government or political party"
         and, if so, the identify of that state, government or party. Please
also revise to clarify
         whether there are any existing or contemplated laws, regulations or
policies that, in light
         of your current and planned operations and composition of management,
directors and
         shareholders, would or could reasonably likely result in a "material
adverse effect," as
         defined in your disclosure. Add any appropriate risk factors.
Shareholders' Agreement, page 119

8.       Please revise to clarify who is a party to this agreement, the nature
and amount of any
         direct or indirect material interest and the rights and obligations of
the parties under the
Related Party
FirstName     Transaction Policy,
           LastNameChristian       page 120
9.         NameHavre
       Please           Global
              describe the      ABand procedures for the review and approval or
ratification of
March related party
       11, 2021 Pagetransactions.
FirstName LastName
 Christian Hanke
FirstName  LastNameChristian Hanke
Havre Global  AB
March      NameHavre Global AB
       11, 2021
March3 11, 2021 Page 3
FirstName LastName
Exclusive Forum, page 122

10.      Please revise to clarify to whom this provision will apply. We note,
for example, the risk
         factor on page 54 addresses only holders of ADSs. Is this provision
limited to holders of
         your ordinary shares? Please also add a risk factor discussing the
risks to investors
         resulting from this provision, if adopted at the meeting to which you
refer. Please disclose
         any uncertainty as to whether courts would enforce the provision. In
this regard, we note
         that Section 22 of the Securities Act creates concurrent jurisdiction
for federal and state
         courts over all suits brought to enforce any duty or liability created
by the Securities Act
         or the rules and regulations thereunder.

11.      We note the disclosure on page (ii) regarding the survey you
commissioned and that you
         cite that survey in this registration statement. Please file the
consent required by Rule 436
         of Regulation C.
12.      Please file as exhibits the employment arrangements mentioned on pages

13.      Please supplementally provide us with copies of all written
communications, as defined in
         Rule 405 under the Securities Act, that you, or anyone authorized to
do so on your behalf,
         present to potential investors in reliance on Section 5(d) of the
Securities Act, whether or
         not they retain copies of the communications. Please contact the staff
member associated
         with this review for guidance on how to submit those materials.
        You may contact Mindy Hooker at (202) 551-3732 or John Cash, Accounting
Chief, at (202) 551-3768 if you have questions regarding comments on the
financial statements
and related matters. Please contact Geoff Kruczek at (202) 551-3641 or Asia
Timmons-Pierce at
(202) 551-3754 with any other questions.


                                                               Division of
Corporation Finance
                                                               Office of
cc:      Marc Jaffe