SEC Comment Letter for SONOCO PRODUCTS CO (SON) (CIK 0000091767) (SON) — Nov 18, 2024
SONOCO PRODUCTS CO (SON) (CIK 0000091767)
Date: Nov. 18, 2024 · CIK: 0000091767 · Accession: 0000000000-24-012711
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File numbers found in text: 001-11261
Letter
November 18, 2024 Robert R. Dillard Chief Financial Officer Sonoco Products Company 1 N. Second Street Hartsville, SC 29550 Re:Sonoco Products Company Form 10-K for the Year Ended December 31, 2024 Form 10-Q for the Quarter Ended June 30, 2024 File No. 001-11261 Dear Robert R. Dillard: We have reviewed your November 14, 2024 response to our comment letter and have the following comment(s). Please respond to this letter within ten business days by providing the requested information or advise us as soon as possible when you will respond. If you do not believe a comment applies to your facts and circumstances, please tell us why in your response. After reviewing your response to this letter, we may have additional comments. Unless we note otherwise, any references to prior comments are to comments in our October 15, 2024 letter. Form 10-Q for the Quarter Ended June 30, 2024 Management's Discussion and Analysis of Financial Condition and Results of Operations Reportable Segments Consumer Packaging, page 51 1.We note your response to prior comment 4. Please revise future filings to disclose the reasons why the metric "productivity" or "productivity savings" is useful to investors, how management uses the metric, and any assumptions underlying the metric or its calculation. See guidance in the SEC's Release No. 33-10751 Commission Guidance on Management’s Discussion and Analysis of Financial Condition and Results of Operations.
November 18, 2024 Page 2 Please contact Heather Clark at 202-551-3624 or Claire Erlanger at 202-551-3301 if you have questions regarding comments on the financial statements and related matters. Sincerely, Division of Corporation Finance Office of Manufacturing
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November 18, 2024
Robert R. Dillard
Chief Financial Officer
Sonoco Products Company
1 N. Second Street
Hartsville, SC 29550
Re:Sonoco Products Company
Form 10-K for the Year Ended December 31, 2024
Form 10-Q for the Quarter Ended June 30, 2024
File No. 001-11261
Dear Robert R. Dillard:
We have reviewed your November 14, 2024 response to our comment letter and have
the following comment(s).
Please respond to this letter within ten business days by providing the requested
information or advise us as soon as possible when you will respond. If you do not believe a
comment applies to your facts and circumstances, please tell us why in your response.
After reviewing your response to this letter, we may have additional comments.
Unless we note otherwise, any references to prior comments are to comments in our October
15, 2024 letter.
Form 10-Q for the Quarter Ended June 30, 2024
Management's Discussion and Analysis of Financial Condition and Results of Operations
Reportable Segments
Consumer Packaging, page 51
1.We note your response to prior comment 4. Please revise future filings to disclose the
reasons why the metric "productivity" or "productivity savings" is useful to investors,
how management uses the metric, and any assumptions underlying the metric or its
calculation. See guidance in the SEC's Release No. 33-10751 Commission Guidance
on Management’s Discussion and Analysis of Financial Condition and Results of
Operations.
November 18, 2024
Page 2
Please contact Heather Clark at 202-551-3624 or Claire Erlanger at 202-551-3301 if
you have questions regarding comments on the financial statements and related matters.
Sincerely,
Division of Corporation Finance
Office of Manufacturing