SEC Comment Letter for INTERCONTINENTAL HOTELS GROUP (IHG) — Aug 2, 2022
INTERCONTINENTAL HOTELS GROUP PLC /NEW/
Date: Aug. 2, 2022 · CIK: 0000858446 · Accession: 0000000000-22-008117
AI Filing Summary & Sentiment
File numbers found in text: 001-10409
Letter
United States securities and exchange commission logo August 2, 2022 Paul Edgecliffe-Johnson Chief Financial Officer InterContinental Hotels Group PLC Broadwater Park Denham, Buckinghamshire UB9 5HR Re:InterContinental Hotels Group PLC Form 20-F for fiscal year ended December 31, 2021 Filed March 3, 2022 File No. 001-10409 Dear Mr. Edgecliffe-Johnson: We have reviewed your July 21, 2022 response to our comment letter and have the following comment. In our comment, we may ask you to provide us with information so we may better understand your disclosure. Please respond to this comment 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 our comment applies to your facts and circumstances, please tell us why in your response. After reviewing your response to this comment, we may have additional comments. Unless we note otherwise, our references to prior comments are to comments in our July 11, 2022 letter. Form 20-F for fiscal year ended December 31, 2021 Group Cash Flow Summary, page 58 1.We note your response to comments 1 and 3. Please reconfigure the reconciliation in Appendix 2 to begin with the most directly comparable measure calculated in accordance with IFRS, which you indicate is Cash flow from operations, to avoid placing undue prominence on the non-IFRS measure. Refer to Item 10(e)(1)(i)(A) of Regulation S-K and Question 102.10 of the Division's Non-GAAP Financial Measures Compliance & Disclosure Interpretations.
FirstName LastNamePaul Edgecliffe-Johnson Comapany NameInterContinental Hotels Group PLC August 2, 2022 Page 2 FirstName LastName Paul Edgecliffe-Johnson InterContinental Hotels Group PLC August 2, 2022 Page 2 You may contact Mark Rakip at (202) 551-3573 or Kristi Marrone at (202) 551-3429 if you have questions regarding comments on the financial statements and related matters. Sincerely, Division of Corporation Finance Office of Real Estate & Construction
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United States securities and exchange commission logo
August 2, 2022
Paul Edgecliffe-Johnson
Chief Financial Officer
InterContinental Hotels Group PLC
Broadwater Park
Denham, Buckinghamshire UB9 5HR
Re:InterContinental Hotels Group PLC
Form 20-F for fiscal year ended December 31, 2021
Filed March 3, 2022
File No. 001-10409
Dear Mr. Edgecliffe-Johnson:
We have reviewed your July 21, 2022 response to our comment letter and have the
following comment. In our comment, we may ask you to provide us with information so we may
better understand your disclosure.
Please respond to this comment 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 our
comment applies to your facts and circumstances, please tell us why in your response.
After reviewing your response to this comment, we may have additional
comments. Unless we note otherwise, our references to prior comments are to comments in our
July 11, 2022 letter.
Form 20-F for fiscal year ended December 31, 2021
Group Cash Flow Summary, page 58
1.We note your response to comments 1 and 3. Please reconfigure the reconciliation in
Appendix 2 to begin with the most directly comparable measure calculated in accordance
with IFRS, which you indicate is Cash flow from operations, to avoid placing undue
prominence on the non-IFRS measure. Refer to Item 10(e)(1)(i)(A) of Regulation S-K
and Question 102.10 of the Division's Non-GAAP Financial Measures Compliance
& Disclosure Interpretations.
FirstName LastNamePaul Edgecliffe-Johnson
Comapany NameInterContinental Hotels Group PLC
August 2, 2022 Page 2
FirstName LastName
Paul Edgecliffe-Johnson
InterContinental Hotels Group PLC
August 2, 2022
Page 2
You may contact Mark Rakip at (202) 551-3573 or Kristi Marrone at (202) 551-3429 if
you have questions regarding comments on the financial statements and related matters.
Sincerely,
Division of Corporation Finance
Office of Real Estate & Construction