SEC Comment Letter for SASOL LTD (SSL, SASOF) (CIK 0000314590) (SSL) — Apr 15, 2008
SASOL LTD (SSL, SASOF) (CIK 0000314590)
Date: April 15, 2008 · CIK: 0000314590 · Accession: 0000000000-08-019522
AI Filing Summary & Sentiment
Referenced dates: March 11, 2008
Letter
UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549-7010 DIVISION OF CORPORATION FINANCE MAIL STOP 7010 April 15, 2008 Ms. Kandimathie Christine Ramon Chief Financial Officer Sasol Limited 1 Sturdee Avenue Rosebank, Johannesburg, 2196 South Africa
Re: Sasol Limited Form 20-F for the Year Ended June 30, 2007 Filed November 21, 2007 Response letter dated March 11, 2008 File No. 1-31615
Dear Ms. Ramon: We have reviewed your response letter and filing and have the following comments. Please provide a written response to our comments. Please be as detailed as necessary in your explanations. After reviewing your response, we may raise additional comments. Form 20-F for the Year Ended June 30, 2007
General
1. Please confirm that in all future filings you will include, to the extent applicable, the disclosure requested below. Operating and Financial Review and Prospects, page 126
2. We note your response to the first bullet of our prior comment 3. Please provide the disclosure set forth in the third paragraph of the first bullet of your response to this comment regarding your building into planned projects your experience in regard to the shortage in the availability and competence of engineering resources. 3. We note your responses to the second bullet of our prior comment 3 and our prior comment 4. Discuss the reasons for the unplanned outages at Sasol Synfuels, the
Ms. Kandimathie Christine Ramon Sasol Limited April 15, 2008 Page 2
duration of the outages, the steps Sasol Synfuels is taking to address the reasons for the outages, and an estimation of costs of remediation, to the extent material. 4. We note your responses to the third and fourth bullets of our prior comment 3 concerning the 20% production capacity expansion of your Synfuels business and Project Mafutha. Provide the costs of the pre-feasibility and feasibility studies undertaken to date relating to these projects and the budget for these studies or other activity regarding these projects for the next fiscal year. Provide the current project schedules.
Closing Comments
Please respond to these comments within 10 business days or tell us when you will provide us with a response. Please furnish a letter that keys your responses to our comments and provides any requested information. Detailed letters greatly facilitate our review. Please understand that we may have additional comments after reviewing your responses to our comments. You may contact Mark Wojciechowski at (202) 551-3759, or in his absence, Kimberly Calder, Assistant Chief Accountant, at (202) 551-3701 if you have questions regarding comments on the financial statements and related matters. Please contact Donna Levy at (202) 551-3292 or me at ( 202) 551-3740 with any other questions. S i n c e r e l y , H . R o g e r S c h w a l l A s s i s t a n t D i r e c t o r
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UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-7010
DIVISION OF
CORPORATION FINANCE MAIL STOP 7010
April 15, 2008
Ms. Kandimathie Christine Ramon Chief Financial Officer Sasol Limited 1 Sturdee Avenue Rosebank, Johannesburg, 2196 South Africa
Re: Sasol Limited
Form 20-F for the Year Ended June 30, 2007 Filed November 21, 2007 Response letter dated March 11, 2008
File No. 1-31615
Dear Ms. Ramon:
We have reviewed your response letter and filing and have the following
comments. Please provide a written response to our comments. Please be as detailed as necessary in your explanations. After reviewing your response, we may raise additional comments. Form 20-F for the Year Ended June 30, 2007
General
1. Please confirm that in all future filings you will include, to the extent applicable, the disclosure requested below.
Operating and Financial Review and Prospects, page 126
2. We note your response to the first bullet of our prior comment 3. Please provide the disclosure set forth in the third paragraph of the first bullet of your response to this comment regarding your building into planned projects your experience in regard to the shortage in the availability and competence of engineering resources.
3. We note your responses to the second bullet of our prior comment 3 and our prior comment 4. Discuss the reasons for the unplanned outages at Sasol Synfuels, the
Ms. Kandimathie Christine Ramon
Sasol Limited April 15, 2008 Page 2
duration of the outages, the steps Sasol Synfuels is taking to address the reasons for the outages, and an estimation of costs of remediation, to the extent material.
4. We note your responses to the third and fourth bullets of our prior comment 3 concerning the 20% production capacity expansion of your Synfuels business and Project Mafutha. Provide the costs of the pre-feasibility and feasibility studies undertaken to date relating to these projects and the budget for these studies or other activity regarding these projects for the next fiscal year. Provide the current project schedules.
Closing Comments
Please respond to these comments within 10 business days or tell us when you will provide us with a response. Please furnish a letter that keys your responses to our comments and provides any requested information. Detailed letters greatly facilitate our review. Please understand that we may have additional comments after reviewing your responses to our comments. You may contact Mark Wojciechowski at (202) 551-3759, or in his absence, Kimberly Calder, Assistant Chief Accountant, at (202) 551-3701 if you have questions regarding comments on the financial statements and related matters. Please contact Donna Levy at (202) 551-3292 or me at ( 202) 551-3740 with any other questions.
S i n c e r e l y , H . R o g e r S c h w a l l A s s i s t a n t D i r e c t o r