SEC Comment Letter for SASOL LTD (SSL, SASOF) (CIK 0000314590) (SSL) — Aug 30, 2016
SASOL LTD (SSL, SASOF) (CIK 0000314590)
Date: Aug. 30, 2016 · CIK: 0000314590 · Accession: 0000000000-16-090686
AI Filing Summary & Sentiment
Letter
Mailstop 4628 August 30 , 201 6 Via E -mail Mr. Bongani Nqwababa Chief Financial Officer Sasol Limited 1 Sturdee Avenue Rosebank 2196, South Africa
Re: Sasol Limited Form 20-F for the Fiscal Year Ended June 30, 2015 Filed October 9 , 2015 File No. 1-31615
Dear Mr. Nqwababa :
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 ten 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.
Form 20-F for the Fiscal Year Ended June 30, 2015
Supplemental Oil and Gas Information (Unaudited), page G -1
Standardized Measure of Discounted Future net Cash Flows Relating to Proved Reserves, page G-9
1. Based on your response to comment one, it appears t hat the contracted transportation capacity reservation costs must be incurred in order to deliver your produced sales gas to market. Given this, it appears that the portion of those costs incurred over the forecast life of your proved reserves should be c onsidered in determining the economic producibility of those reserves. To the extent that the revenue from your proved reserves does not offset the costs of operation, including applicable transportation costs, the
Mr. Bongani Nqwababa Sasol Limited August 30 , 2016
quantities would not be considered econo mically producible and should not be reported as proved reserves.
2. Please expand your disclosure to provide a n explanation for the negative undiscounted future net cash flows relating to proved reserves for Canada and Gabon. Refer to FASB ASC 932 -235-50-36.
You may contact Lily Dang at (202) 551 -3867 if you have questions regarding comments on the financial statements and related matters. You may contact John Hodgin, Petroleum Engineer, at (202) 551 -3699 if you have questions regarding the engineerin g comments . Please contact me at (202) 551 -3489 with any other questions.
Sincerely,
/s/ Brad Skinner
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Mailstop 4628
August 30 , 201 6
Via E -mail
Mr. Bongani Nqwababa
Chief Financial Officer
Sasol Limited
1 Sturdee Avenue
Rosebank 2196, South Africa
Re: Sasol Limited
Form 20-F for the Fiscal Year Ended June 30, 2015
Filed October 9 , 2015
File No. 1-31615
Dear Mr. Nqwababa :
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 ten 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.
Form 20-F for the Fiscal Year Ended June 30, 2015
Supplemental Oil and Gas Information (Unaudited), page G -1
Standardized Measure of Discounted Future net Cash Flows Relating to Proved Reserves, page
G-9
1. Based on your response to comment one, it appears t hat the contracted transportation
capacity reservation costs must be incurred in order to deliver your produced sales gas to
market. Given this, it appears that the portion of those costs incurred over the forecast
life of your proved reserves should be c onsidered in determining the economic
producibility of those reserves. To the extent that the revenue from your proved reserves
does not offset the costs of operation, including applicable transportation costs, the
Mr. Bongani Nqwababa
Sasol Limited
August 30 , 2016
quantities would not be considered econo mically producible and should not be reported
as proved reserves.
2. Please expand your disclosure to provide a n explanation for the negative undiscounted
future net cash flows relating to proved reserves for Canada and Gabon. Refer to FASB
ASC 932 -235-50-36.
You may contact Lily Dang at (202) 551 -3867 if you have questions regarding comments
on the financial statements and related matters. You may contact John Hodgin, Petroleum
Engineer, at (202) 551 -3699 if you have questions regarding the engineerin g comments . Please
contact me at (202) 551 -3489 with any other questions.
Sincerely,
/s/ Brad Skinner
Brad Skinner
Senior Assistant Chief Accountant
Office of Natural Resources