SEC Comment Letter for SONOCO PRODUCTS CO (SON) (CIK 0000091767) (SON) — Aug 26, 2015
SONOCO PRODUCTS CO (SON) (CIK 0000091767)
Date: Aug. 26, 2015 · CIK: 0000091767 · Accession: 0000000000-15-043102
AI Filing Summary & Sentiment
Letter
Mail Stop 4628 August 14, 2015 Via E -mail Barry L. Saunders Chief Financial Officer Sonoco Products Company 1 North Second Street Hartsville, South Carolina 29550
Re: Sonoco Products Company Form 8 -K Filed August 10 , 2015 File No. 1-11261
Dear Mr. Saunders :
We have reviewed your filing an d 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 these comments within five busine ss days by providing the requested information or advis e us as soon as possible when you will respond. If you do not believe our comments apply to your facts and circumstances, please tell us why in your response.
After reviewing your response to these comments, we may have additional comments.
Item 4.02 Form 8 -K filed August 10, 2015
1. We note that your Audit Committee concluded on August 9, 2015 that your financial statements for the per iods identified in your filing should be restated and therefore should no longer be relied upon. We also note your disclosure in the Form 8 -K filed on July 16, 2015 which indicates that you expected changes to your historical consolidated financial statem ents. Disclosure in this Form 8 -K also addresses and quantifies expected adjustments to your pre -tax earnings for the three years ending December 31, 2014. Please tell us how you determined that it was not necessary to file an Item 4.02 Form 8 -K until Au gust 10, 2015. As part of your response, provide us with a timeline for the matter addressed in your Form 8 -K beginning on the date when it was initially identified.
We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filing to be certain that the filing includes the information the Securities Exchange Act of 1934 and all applicable Exchange Act rules require. Since the company and its management are
Barry L. Saunders Sonoco Products Company August 14, 2015 Page 2
in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy and adequacy of the disclosures they have made.
In responding to our comments, please provide a written statement from the company acknowledging that:
the company is responsible for the adequacy and accuracy of the disclosure in the filing;
staff comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to the filing; and
the company may not assert staff comments as a defense in any proce eding initiated by the Commission or any person under the federal securities laws of the United States.
You may contact Diane Fritz , Staff Accountant, at (202) 551 -3331 or me at (202) 551 - 3311 with any questions. Sincerely,
/s/ Ethan Horowitz
Ethan Horowitz Branch Chief Office of Natural Resources
Show Raw Text
Mail Stop 4628
August 14, 2015
Via E -mail
Barry L. Saunders
Chief Financial Officer
Sonoco Products Company
1 North Second Street
Hartsville, South Carolina 29550
Re: Sonoco Products Company
Form 8 -K
Filed August 10 , 2015
File No. 1-11261
Dear Mr. Saunders :
We have reviewed your filing an d 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 these comments within five busine ss days by providing the requested
information or advis e us as soon as possible when you will respond. If you do not believe our
comments apply to your facts and circumstances, please tell us why in your response.
After reviewing your response to these comments, we may have additional comments.
Item 4.02 Form 8 -K filed August 10, 2015
1. We note that your Audit Committee concluded on August 9, 2015 that your financial
statements for the per iods identified in your filing should be restated and therefore should
no longer be relied upon. We also note your disclosure in the Form 8 -K filed on July 16,
2015 which indicates that you expected changes to your historical consolidated financial
statem ents. Disclosure in this Form 8 -K also addresses and quantifies expected
adjustments to your pre -tax earnings for the three years ending December 31, 2014.
Please tell us how you determined that it was not necessary to file an Item 4.02 Form 8 -K
until Au gust 10, 2015. As part of your response, provide us with a timeline for the matter
addressed in your Form 8 -K beginning on the date when it was initially identified.
We urge all persons who are responsible for the accuracy and adequacy of the disclosure
in the filing to be certain that the filing includes the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules require. Since the company and its management are
Barry L. Saunders
Sonoco Products Company
August 14, 2015
Page 2
in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy
and adequacy of the disclosures they have made.
In responding to our comments, please provide a written statement from the company
acknowledging that:
the company is responsible for the adequacy and accuracy of the disclosure in the filing;
staff comments or changes to disclosure in response to staff comments do not foreclose
the Commission from taking any action with respect to the filing; and
the company may not assert staff comments as a defense in any proce eding initiated by
the Commission or any person under the federal securities laws of the United States.
You may contact Diane Fritz , Staff Accountant, at (202) 551 -3331 or me at (202) 551 -
3311 with any questions.
Sincerely,
/s/ Ethan Horowitz
Ethan Horowitz
Branch Chief
Office of Natural Resources