Correspondence 0000835403-24-000012 from DIAGEO PLC (DEO, DGEAF) (CIK 0000835403) (DEO)
DIAGEO PLC (DEO, DGEAF) (CIK 0000835403)
Date: March 26, 2024 · CIK: 0000835403 · Accession: 0000835403-24-000012
AI Filing Summary & Sentiment
File numbers found in text: 001-10691
Referenced dates: March 12, 2024
Letter
Document
March 26, 2024
By EDGAR Submission
Securities and Exchange Commission
100 F. Street, N.E.
Washington, D.C. 20549
Attention:
Eiko Yaoita Pyles
Melissa Gilmore
Division of Corporation Finance, Office of Manufacturing
Re: Diageo plc
Form 20-F for the fiscal year ended June 30, 2023
Filed August 3, 2023
File No. 001-10691
Ladies and Gentleman,
Diageo plc (“Diageo” or “we”) is submitting this letter in response to the written comments of the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”), dated March 12, 2024 (the “Comment Letter”), on Diageo’s Annual Report on Form 20-F filed with the Commission on August 3, 2023 for the fiscal year ended June 30, 2023 (the “Form 20-F”).
Set forth below is the heading and text of the Staff’s comment followed by our response.
Operating results 2023 compared with 2022
Income statement, page 66
We note that the table here is labelled “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.
Response
We respectfully acknowledge the Staff’s comment and respectfully advise the Staff that attached as Exhibit A is a template form of the table that the Company intends to use going forward to help explain movements in selected financial data from the prior year to the current year.
* * *
Please do not hesitate to contact me at Lavanya.Chandrashekar@diageo.com with any questions or comments you may have.
Very truly yours,
/s/ Lavanya Chandrashekar
Show Raw Text
CORRESP 1 filename1.htm Document March 26, 2024 By EDGAR Submission Securities and Exchange Commission 100 F. Street, N.E. Washington, D.C. 20549 Attention: Eiko Yaoita Pyles Melissa Gilmore Division of Corporation Finance, Office of Manufacturing Re: Diageo plc Form 20-F for the fiscal year ended June 30, 2023 Filed August 3, 2023 File No. 001-10691 Ladies and Gentleman, Diageo plc (“Diageo” or “we”) is submitting this letter in response to the written comments of the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”), dated March 12, 2024 (the “Comment Letter”), on Diageo’s Annual Report on Form 20-F filed with the Commission on August 3, 2023 for the fiscal year ended June 30, 2023 (the “Form 20-F”). Set forth below is the heading and text of the Staff’s comment followed by our response. Operating results 2023 compared with 2022 Income statement, page 66 We note that the table here is labelled “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. Response We respectfully acknowledge the Staff’s comment and respectfully advise the Staff that attached as Exhibit A is a template form of the table that the Company intends to use going forward to help explain movements in selected financial data from the prior year to the current year. * * * Please do not hesitate to contact me at Lavanya.Chandrashekar@diageo.com with any questions or comments you may have. Very truly yours, /s/ Lavanya Chandrashekar Lavanya Chandrashekar Chief Financial Officer Cc: Tom Shropshire, General Counsel and Company Secretary Connie Milonakis (Davis Polk & Wardwell London LLP) Scott Berryman (PricewaterhouseCoopers LLP) Exhibit A Proposed illustrative reformatted and renamed “Key financials––certain line items” table (using as a reference, information from our 2023 “Income Statement” table in our Annual Report on Form 20-F for the Fiscal Year Ended June 30, 2023 filed on August 3, 2023): Key financials – certain line items Reported 30 June 2022 £ million Exceptional items £ million Adjusted 30 June 2022 £ million Exchange £ million Acquisitions and disposals £ million Organic movement £ million Fair value remeasurement £ million Hyperinflation £ million Adjusted 30 June 2023 £ million Exceptional items £ million Reported 30 June 2023 £ million Sales 22,448 — 22,448 588 (683) 1,091 — 71 23,515 — 23,515 Excise duties (6,996) — (6,996) 114 569 (122) — 33 (6,402) — (6,402) Net sales 15,452 — 15,452 702 (114) 969 — 104 17,113 — 17,113 Cost of sales (5,973) — (5,973) (363) 84 (522) 5 (63) (6,832) (67) (6,899) Gross profit 9,479 — 9,479 339 (30) 447 5 41 10,281 (67) 10,214 Marketing (2,721) — (2,721) (151) (15) (152) (1) (11) (3,051) — (3,051) Other operating items (2,349) (388) (1,961) (66) (16) 26 49 (8) (1,976) (555) (2,531) Operating profit 4,409 (388) 4,797 122 (61) 321 53 22 5,254 (622) 4,632 Other line items: Non-operating items (17) (17) — — 328 328 Taxation (1,049) 31 (1,080) (1,156) 186 (970)