SecProbe.io

November 18, 2024
John Rogers
Chief Financial Officer
SMITH & NEPHEW PLC
Building 5, Croxley Park, Hatters Lane
Watford, Hertfordshire WD18 8YE
Re:SMITH & NEPHEW PLC
Form 20-F filed March 11, 2024
Response filed November 8, 2024
File No. 001-14978
Dear John Rogers:
            We have reviewed your November 8, 2024 response to our comment letter and have
the following comments.
            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 October
11, 2024 letter.
Form 20-F for the Fiscal Year Ended December 31, 2023
Note 2 Business segment information, page 180
We note your response to prior comment 2. Please more fully explain your statement
that "...aggregating these operating segments into a single operating segment (which is
itself also a reportable segment) is acceptable because such presentation most properly
reflects its operations and because separate reporting of such segment information
would not significantly enhance an investor’s understanding of the Company’s
business, financial position and operating results." Ensure your response addresses the
following:
We note that the internal reorganization in 2023 resulted in the appointment of
separate Presidents for Sports Medicine and ENT while previously Sports
Medicine and ENT were led by one individual. Explain your reasons for
the reorganization. In light of this reorganization, explain why you believe the •1.

November 18, 2024
Page 2
aggregation of these operating segments reflects your current operations.
•To support your belief that the Sports Medicine and ENT operating segments are
economically similar and that separate reporting would not significantly enhance
an investor’s understanding of the Company’s business, financial position and
operating results, please supplementally provide us with revenues from external
customers, segment profit and gross profit for Sports Medicine and ENT for the
last 5 fiscal years. Your response should address any discrepancies in the trends
depicted.
Note 17 Provisions and contingences, page 211
2.We note your response to prior comment 7 and have the following additional
comments:
•With regard to the Operations and Commercial Excellence programme
(programme), please provide additional information regarding how you
reorganised your supply chain and selling model.  Quantify the number of
manufacturing sites closed and remaining number of manufacturing sites. Identify
the markets that underwent the reorganisation of your selling model and indicate
how large those markets were in comparison to your total total market.
•With regard to the 12-Point Plan (the plan), please provide us with the underlying
activities performed to fix Orthopaedics, improve productivity and accelerate
growth.
•With reference to this expanded information, more fully address, for both the
programme and plan, how these activities fall within the events identified in IAS
37.10 and IAS 37.70 such that they meet the definition of a restructuring.
•Separately present the costs presented in your response for the programme and
plan.
•Please provide us with additional information, for both the programme and plan,
regarding the specific activities or events underlying the business advisory
services, integration and dual running and contractual terminations.  Address
whether these were internal or external costs.
            Please contact Jeanne Baker at 202-551-3691 or Al Pavot at 202-551-3738 if you
have questions regarding comments on the financial statements and related matters.
Sincerely,
Division of Corporation Finance
Office of Industrial Applications and
Services