SEC Comment Letter 0000000000-23-002048 to UNIFIRST CORP (UNF) (CIK 0000717954) (UNF)
UNIFIRST CORP (UNF) (CIK 0000717954)
Date: March 1, 2023 · CIK: 0000717954 · Accession: 0000000000-23-002048
AI Filing Summary & Sentiment
File numbers found in text: 001-08504
Letter
United States securities and exchange commission logo March 1, 2023 Shane O’Connor Chief Financial Officer UniFirst Corporation 68 Jonspin Road Wilmington, MA 01887 Re:UniFirst Corporation Form 10-K for Fiscal Year Ended August 27, 2022 Filed October 26, 2022 Form 8-K Furnished October 19, 2022 File No. 001-08504 Dear Shane O’Connor: We have reviewed your filings and 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 business days by providing the requested information or advise 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 10-K for Fiscal Year Ended August 27, 2022 Item 7. Management's Discussion and Analysis Fiscal Year Ended August 27, 2022 Compared with Fiscal Year Ended August 28, 2021, page 28 1.Where you identify two or more factors which contributed to material changes in financial statement line items, please expand your disclosures to quantify the individual impact of each factor. In this regard, we note you have identified multiple factors contributing to the increases in revenues and cost of revenues for your Core Laundry Operations' without quantification of the factors cited. Additionally, to the extent your results have been impacted by the current inflationary environment, please provide the impact in quantitative terms, to the extent practicable. Please note this comment applies to all future periodic reporting, as we note similar instances in your Form 10-Q for the period ended November 26, 2022. Refer to Item 303(b) of Regulation S-K.
FirstName LastNameShane O’Connor Comapany NameUniFirst Corporation March 1, 2023 Page 2 FirstName LastName Shane O’Connor UniFirst Corporation March 1, 2023 Page 2 Form 8-K Furnished October 19, 2022 Exhibit 99, page 1 2.We note you present certain non-GAAP measures which remove the impacts related to your "Key Initiatives." On page 28 of your FY 2022 Form 10-K, you state these initiatives are a focus over the next few years, and include costs related to your CRM system, investments in the UniFirst brand, and ERP system. Please tell us your consideration of Question 100.01 of the staff's Compliance & Disclosure Interpretations on Non-GAAP Financial Measures "C&DI's" in determining the appropriateness of each component comprising your key initiatives adjustment. Also, please refer to Item 10(e)(1)(ii)(B) of Regulation S-K and Question 102.03 of the non-GAAP C&DI's in regards to your statement describing these excluded costs as "non-recurring." We remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff. You may contact Abe Friedman at 202-551-8298 or Lyn Shenk at 202-551-3380 with any questions. Sincerely, Division of Corporation Finance Office of Trade & Services
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United States securities and exchange commission logo
March 1, 2023
Shane O’Connor
Chief Financial Officer
UniFirst Corporation
68 Jonspin Road
Wilmington, MA 01887
Re:UniFirst Corporation
Form 10-K for Fiscal Year Ended August 27, 2022
Filed October 26, 2022
Form 8-K Furnished October 19, 2022
File No. 001-08504
Dear Shane O’Connor:
We have reviewed your filings and 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 business days by providing the requested
information or advise 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 10-K for Fiscal Year Ended August 27, 2022
Item 7. Management's Discussion and Analysis
Fiscal Year Ended August 27, 2022 Compared with Fiscal Year Ended August 28, 2021, page 28
1.Where you identify two or more factors which contributed to material changes in financial
statement line items, please expand your disclosures to quantify the individual impact of
each factor. In this regard, we note you have identified multiple factors contributing to the
increases in revenues and cost of revenues for your Core Laundry Operations' without
quantification of the factors cited. Additionally, to the extent your results have been
impacted by the current inflationary environment, please provide the impact in
quantitative terms, to the extent practicable. Please note this comment applies to all future
periodic reporting, as we note similar instances in your Form 10-Q for the period ended
November 26, 2022. Refer to Item 303(b) of Regulation S-K.
FirstName LastNameShane O’Connor
Comapany NameUniFirst Corporation
March 1, 2023 Page 2
FirstName LastName
Shane O’Connor
UniFirst Corporation
March 1, 2023
Page 2
Form 8-K Furnished October 19, 2022
Exhibit 99, page 1
2.We note you present certain non-GAAP measures which remove the impacts related to
your "Key Initiatives." On page 28 of your FY 2022 Form 10-K, you state these
initiatives are a focus over the next few years, and include costs related to your CRM
system, investments in the UniFirst brand, and ERP system. Please tell us your
consideration of Question 100.01 of the staff's Compliance & Disclosure Interpretations
on Non-GAAP Financial Measures "C&DI's" in determining the appropriateness of each
component comprising your key initiatives adjustment. Also, please refer to
Item 10(e)(1)(ii)(B) of Regulation S-K and Question 102.03 of the non-GAAP C&DI's in
regards to your statement describing these excluded costs as "non-recurring."
We remind you that the company and its management are responsible for the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action or absence of
action by the staff.
You may contact Abe Friedman at 202-551-8298 or Lyn Shenk at 202-551-3380 with
any questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services