Correspondence 0001104659-24-122115 from SONOCO PRODUCTS CO (SON)
SONOCO PRODUCTS CO
Date: Nov. 22, 2024 · CIK: 0000091767 · Accession: 0001104659-24-122115
AI Filing Summary & Sentiment
File numbers found in text: 001-11261
Referenced dates: November 14, 2024, October 15, 2024
Letter
VIA EDGAR RE: Sonoco Products Company Form 10-K for the Year Ended December 31, 2023 Form 10-Q for the Quarter Ended June 30, 2024 File No. 001-11261
Dear Ms. Clark and Ms. Erlanger:
On behalf of Sonoco Products Company (the “Company”), we submit this letter in response to comments from the Staff of the Division of Corporation Finance, Office of Manufacturing (the “Staff”) of the Securities and Exchange Commission (the “Commission”) dated November 18, 2024, issued in response to the Company’s letter dated November 14, 2024 in response to the Staff’s initial comment letter dated October 15, 2024, all relating to the Company’s Annual Report on Form 10-K for the year ended December 31, 2023 and the Company’s Quarterly Report on Form 10-Q for the quarter ended June 30, 2024. In this letter, we have recited the comment from the Staff in italicized type and have followed each comment with the Company’s response.
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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 reasons why the metric “productivity” or “productivity savings” is useful to investors, how managements 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.
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The Company acknowledges the Staff’s comment and advises the Staff that it will follow the guidance in the SEC’s Release no. 33-10751, Commission Guidance on Management’s Discussion and Analysis of Financial Condition and Results of Operations, and will revise its future filings, beginning with its Annual Report on Form 10-K for the year ending December 31, 2024, to disclose 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.
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We hope that the foregoing has been responsive to the Staff’s comment and look forward to resolving any outstanding issues as quickly as possible. Please do not hesitate to contact me at (212) 277-4016 with any questions or comments regarding this filing or if you wish to discuss the above.
Sincerely,
Pamela Marcogliese
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VIA EDGAR
U.S. Securities and Exchange Commission
Division of Corporation Finance
Office of Manufacturing
100 F Street, N.E.
Washington, D.C. 20549
Attn: Heather Clark and Claire Erlanger
New York
3 World Trade Center
175 Greenwich Street
New York, NY 10007
Pamela Marcogliese
T +1 (212) 277-4000
T +1 (212) 277-4016 (direct)
E pamela.marcogliese@freshfields.com
freshfields.us
November 22, 2024
Doc
ID - US-LEGAL-13157989/3
Our Ref - 174909-0002 PLM
RE: Sonoco Products Company
Form 10-K for
the Year Ended December 31, 2023
Form 10-Q for
the Quarter Ended June 30, 2024
File No. 001-11261
Dear Ms. Clark and Ms. Erlanger:
On behalf of Sonoco Products Company
(the “Company”), we submit this letter in response to comments from the Staff of the Division of Corporation
Finance, Office of Manufacturing (the “Staff”) of the Securities and Exchange Commission (the “Commission”)
dated November 18, 2024, issued in response to the Company’s letter dated November 14, 2024 in response to the Staff’s initial
comment letter dated October 15, 2024, all relating to the Company’s Annual Report on Form 10-K for the year ended December 31,
2023 and the Company’s Quarterly Report on Form 10-Q for the quarter ended June 30, 2024. In this letter, we have recited the comment
from the Staff in italicized type and have followed each comment with the Company’s response.
********************************************
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 reasons why
the metric “productivity” or “productivity savings” is useful to
investors, how managements 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.
2
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The Company acknowledges the Staff’s
comment and advises the Staff that it will follow the guidance in the SEC’s Release no. 33-10751, Commission Guidance on Management’s
Discussion and Analysis of Financial Condition and Results of Operations, and will revise its future filings, beginning with its
Annual Report on Form 10-K for the year ending December 31, 2024, to disclose 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.
********************************************
We hope that the foregoing has been
responsive to the Staff’s comment and look forward to resolving any outstanding issues as quickly as possible. Please do not hesitate
to contact me at (212) 277-4016 with any questions or comments regarding this filing or if you wish to discuss the above.
Sincerely,
Pamela Marcogliese
cc: R. Howard Coker, President and
Chief Executive Officer, Sonoco Products Company
Robert R. Dillard,
Chief Financial Officer, Sonoco Products Company
Aditya Gandhi, Vice
President and Chief Accounting Officer, Sonoco Products Company
John M. Florence, Jr., General
Counsel, Secretary, Vice President and General Manager Converted Products North America, Sonoco Products Company