SEC Comment Letter 0000000000-24-002699 to DIAGEO PLC (DEO, DGEAF) (CIK 0000835403) (DEO)
DIAGEO PLC (DEO, DGEAF) (CIK 0000835403)
Date: March 12, 2024 · CIK: 0000835403 · Accession: 0000000000-24-002699
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File numbers found in text: 001-10691
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United States securities and exchange commission logo
March 12, 2024
Lavanya Chandrashekar
Chief Financial Officer
Diageo plc
16 Great Marlborough Street
London W1F 7HS, England
Re:Diageo plc
Form 20-F for the fiscal year ended June 30, 2023
Filed August 3, 2023
File No. 001-10691
Dear Lavanya Chandrashekar:
We have limited our review of your filing to the financial statements and related
disclosures and have the following comment.
Please respond to this letter 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 a
comment applies to your facts and circumstances, please tell us why in your response.
After reviewing your response to this letter, we may have additional comments.
Form 20-F for the fiscal year ended June 30, 2023
Operating results 2023 compared with 2022
Income statement, page 66
1.We note that the table here is labeled “income statement”. This table appear to include
line items which are not permitted to separately present in an income statement under
IFRS (e.g., operating profit before exceptional items). In future filings, please remove or
explain why you do not believe such change should be made. Refer to
Item 10(e)(1)(ii)(C) of Regulation S-K.
FirstName LastNameLavanya Chandrashekar
Comapany NameDiageo plc
March 12, 2024 Page 2
FirstName LastName
Lavanya Chandrashekar
Diageo plc
March 12, 2024
Page 2
In closing, 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.
Please contact Eiko Yaoita Pyles at 202-551-3587 or Melissa Gilmore at 202-551-3777
with any questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing