SEC Comment Letter 0000000000-24-003668 to DIAGEO PLC (DEO, DGEAF) (CIK 0000835403) (DEO)
DIAGEO PLC (DEO, DGEAF) (CIK 0000835403)
Date: April 5, 2024 · CIK: 0000835403 · Accession: 0000000000-24-003668
AI Filing Summary & Sentiment
File numbers found in text: 001-10691
Letter
United States securities and exchange commission logo April 5, 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 reviewed your March 26, 2024 response to our comment letter 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. Unless we note otherwise, any references to prior comments are to comments in our March 12, 2024 letter. 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 line items for “Adjusted” columns of the template form of the table you provided in response to prior comment 1, appear to present a substantially full income statement of non-GAAP measures. Please tell us your consideration of Question 102.10 of the Compliance and Disclosure Interpretations on Non-GAAP Financial Measures and Item 10(e)(1)(i)(A) of Regulation S-K and tell us how you will apply the guidance accordingly in future filings.
FirstName LastNameLavanya Chandrashekar Comapany NameDiageo plc April 5, 2024 Page 2 FirstName LastName Lavanya Chandrashekar Diageo plc April 5, 2024 Page 2 Please contact Eiko Yaoita Pyles at 202-551-3587 or Melissa Gilmore at 202-551-3777 if you have questions regarding comments on the financial statements and related matters. Sincerely, Division of Corporation Finance Office of Manufacturing
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United States securities and exchange commission logo
April 5, 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 reviewed your March 26, 2024 response to our comment letter 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. Unless
we note otherwise, any references to prior comments are to comments in our March 12, 2024
letter.
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 line items for “Adjusted” columns of the template form of the table you
provided in response to prior comment 1, appear to present a substantially full income
statement of non-GAAP measures. Please tell us your consideration of Question 102.10 of
the Compliance and Disclosure Interpretations on Non-GAAP Financial Measures and
Item 10(e)(1)(i)(A) of Regulation S-K and tell us how you will apply the guidance
accordingly in future filings.
FirstName LastNameLavanya Chandrashekar
Comapany NameDiageo plc
April 5, 2024 Page 2
FirstName LastName
Lavanya Chandrashekar
Diageo plc
April 5, 2024
Page 2
Please contact Eiko Yaoita Pyles at 202-551-3587 or Melissa Gilmore at 202-551-3777 if
you have questions regarding comments on the financial statements and related matters.
Sincerely,
Division of Corporation Finance
Office of Manufacturing