SEC Company Response from WPP plc (WPP, WPPGF) (CIK 0000806968) (WPP) — Jan 19, 2018
WPP plc (WPP, WPPGF) (CIK 0000806968)
Date: Jan. 19, 2018 · CIK: 0000806968 · Accession: 0001193125-18-014676
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 000-16350
Referenced dates: November 14, 2017, November 20, 2017
Letter
Securities and Exchange Commission Division of Corporation Finance Re: WPP plc Form 20-F for the Fiscal Year Ended December 31, 2016 Filed April 28, 2017 File No. 000-16350
Dear Mr. Pacho:
On behalf of WPP plc (the “Company”), this letter responds to the comment received from the Division of Corporation Finance of the Securities and Exchange Commission (the “Commission”) in a letter dated November 20, 2017 (the “Comment Letter”) pertaining to the captioned report on Form 20-F and the Company’s response letter dated November 14, 2017. For ease of reference in this letter, the Commission’s comment contained in the Comment Letter is reproduced in bold, and the response of the Company is shown below such comment. We note that the below question makes reference to the Company’s Consolidated Income Statement, page F-8.
1. We note your response to comment one. Please provide us with a schedule showing your proposed revised income statement presentation for the last two fiscal years.
A schedule showing the proposed revised income statement presentation for the last two fiscal years is included below. Please note that this schedule is provisional and therefore subject to finalization following completion of the audit.
Carlos Pacho
Securities and Exchange Commission
January 19, 2018
Page
Consolidated income statement
For the years ended 31 December 2016, 2015
£m
£m
Revenue
14,388.9
12,235.2
Direct costs of services
(1,991.1 )
(1,710.9 )
Revenue less direct costs of services
12,397.8
10,524.3
Other costs of services
(9,357.0 )
(7,998.3 )
Gross profit
3,040.8
2,526.0
General and administrative costs
(977.7 )
(894.0 )
Operating profit
2,063.1
1,632.0
Share of results of associates
49.8
47.0
Profit before interest and taxation
2,112.9
1,679.0
Finance income
80.4
72.4
Finance costs
(254.5 )
(224.1 )
Revaluation of financial instruments
(48.3 )
(34.7 )
Profit before taxation
1,890.5
1,492.6
Taxation
(388.9 )
(247.5 )
Profit for the year
1,501.6
1,245.1
Attributable to:
Equity holders of the parent
1,400.1
1,160.2
Non-controlling interests
101.5
84.9
1,501.6
1,245.1
Earnings per share
Basic earnings per ordinary share
109.6p
90.0p
Diluted earnings per ordinary share
108.0p
88.4p
* * * *
On behalf of the Company we acknowledge 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.
Please do not hesitate to contact the undersigned at (212) 468-4944 if you have any further comments or questions.
Very truly yours,
/s/ Ralph W. Norton
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CORRESP 1 filename1.htm Response Letter 1740 Broadway T: 212.468.4800 www.dglaw.com New York, NY 10019 F: 212.468.4888 Direct Dial: 212.468.4944 Personal Fax: 212.974.6969 Email: rnorton@dglaw.com January 19, 2018 Carlos Pacho Senior Assistant Chief Accountant AD Office 11 – Telecommunications Securities and Exchange Commission Division of Corporation Finance 100 F Street, N.E. Washington, D.C. 20549 Re: WPP plc Form 20-F for the Fiscal Year Ended December 31, 2016 Filed April 28, 2017 File No. 000-16350 Dear Mr. Pacho: On behalf of WPP plc (the “Company”), this letter responds to the comment received from the Division of Corporation Finance of the Securities and Exchange Commission (the “Commission”) in a letter dated November 20, 2017 (the “Comment Letter”) pertaining to the captioned report on Form 20-F and the Company’s response letter dated November 14, 2017. For ease of reference in this letter, the Commission’s comment contained in the Comment Letter is reproduced in bold, and the response of the Company is shown below such comment. We note that the below question makes reference to the Company’s Consolidated Income Statement, page F-8. 1. We note your response to comment one. Please provide us with a schedule showing your proposed revised income statement presentation for the last two fiscal years. A schedule showing the proposed revised income statement presentation for the last two fiscal years is included below. Please note that this schedule is provisional and therefore subject to finalization following completion of the audit. Carlos Pacho Securities and Exchange Commission January 19, 2018 Page 2 Consolidated income statement For the years ended 31 December 2016, 2015 2016 £m 2015 £m Revenue 14,388.9 12,235.2 Direct costs of services (1,991.1 ) (1,710.9 ) Revenue less direct costs of services 12,397.8 10,524.3 Other costs of services (9,357.0 ) (7,998.3 ) Gross profit 3,040.8 2,526.0 General and administrative costs (977.7 ) (894.0 ) Operating profit 2,063.1 1,632.0 Share of results of associates 49.8 47.0 Profit before interest and taxation 2,112.9 1,679.0 Finance income 80.4 72.4 Finance costs (254.5 ) (224.1 ) Revaluation of financial instruments (48.3 ) (34.7 ) Profit before taxation 1,890.5 1,492.6 Taxation (388.9 ) (247.5 ) Profit for the year 1,501.6 1,245.1 Attributable to: Equity holders of the parent 1,400.1 1,160.2 Non-controlling interests 101.5 84.9 1,501.6 1,245.1 Earnings per share Basic earnings per ordinary share 109.6p 90.0p Diluted earnings per ordinary share 108.0p 88.4p * * * * On behalf of the Company we acknowledge 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. Please do not hesitate to contact the undersigned at (212) 468-4944 if you have any further comments or questions. Very truly yours, /s/ Ralph W. Norton Cc: Andrea Harris, Esq.