SEC Comment Letter 0000000000-23-013861 to ManpowerGroup Inc. (MAN) (CIK 0000871763) (MAN)
ManpowerGroup Inc. (MAN) (CIK 0000871763)
Date: Dec. 19, 2023 · CIK: 0000871763 · Accession: 0000000000-23-013861
AI Filing Summary & Sentiment
File numbers found in text: 001-10686
Letter
United States securities and exchange commission logo December 19, 2023 John McGinnis Executive Vice President and Chief Financial Officer ManpowerGroup Inc. 100 Manpower Place Milwaukee, WI 53212 Re:ManpowerGroup Inc. Form 10-K for Fiscal Year Ended December 31, 2022 Form 8-K furnished October 19, 2023 File No. 001-10686 Dear John McGinnis: We have limited our review of your filing to the financial statements and related disclosures 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. Form 10-K for Fiscal Year Ended December 31, 2022 Item 7. Management's Discussion and Analysis Consolidated Results - 2022 compared to 2021 Segment Results, page 37 1.Please revise to provide quantification of factors to which changes are attributed in absolute dollar amounts, to the extent providing such quantification would provide meaningful analysis of your year over year results. For example, your discussions of revenue and gross profit for your Americas segment discusses multiple factors without quantification that would allow users to understand the impact of each material factor. Also, certain discussions do not appear to discuss or quantify all material factors that impacted your year over year results. Specifically, when discussing you Northern Europe results, you attribute your OUP margin decrease to the loss on sale of your Russia business partially offset by the increase in gross profit margin. Your discussion focuses on the decreased OUP margin without quantified discussion on what caused your Northern Europe Operating Unit Profit ("Organic Constant Currency Variance") to
FirstName LastNameJohn McGinnis Comapany NameManpowerGroup Inc. December 19, 2023 Page 2 FirstName LastName John McGinnis ManpowerGroup Inc. December 19, 2023 Page 2 decrease by 22.3%. Refer to Item 303 of Regulation S-K. Form 8-K furnished October 19, 2023 Exhibit 99.1, page 1 2.You present a non-GAAP measure of Free Cash Flow in the initial bullet points of your earnings release. Please revise to include the disclosures required by Item 10(e)(1)(i) of Regulation S-K. 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 Robert Shapiro at 202-551-3273 or Abe Friedman at 202-551-8298 with any questions. Sincerely, Division of Corporation Finance Office of Trade & Services
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United States securities and exchange commission logo
December 19, 2023
John McGinnis
Executive Vice President and Chief Financial Officer
ManpowerGroup Inc.
100 Manpower Place
Milwaukee, WI 53212
Re:ManpowerGroup Inc.
Form 10-K for Fiscal Year Ended December 31, 2022
Form 8-K furnished October 19, 2023
File No. 001-10686
Dear John McGinnis:
We have limited our review of your filing to the financial statements and related
disclosures 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.
Form 10-K for Fiscal Year Ended December 31, 2022
Item 7. Management's Discussion and Analysis
Consolidated Results - 2022 compared to 2021
Segment Results, page 37
1.Please revise to provide quantification of factors to which changes are attributed in
absolute dollar amounts, to the extent providing such quantification would provide
meaningful analysis of your year over year results. For example, your discussions of
revenue and gross profit for your Americas segment discusses multiple factors without
quantification that would allow users to understand the impact of each material
factor. Also, certain discussions do not appear to discuss or quantify all material factors
that impacted your year over year results. Specifically, when discussing you Northern
Europe results, you attribute your OUP margin decrease to the loss on sale of your Russia
business partially offset by the increase in gross profit margin. Your discussion focuses
on the decreased OUP margin without quantified discussion on what caused your
Northern Europe Operating Unit Profit ("Organic Constant Currency Variance") to
FirstName LastNameJohn McGinnis
Comapany NameManpowerGroup Inc.
December 19, 2023 Page 2
FirstName LastName
John McGinnis
ManpowerGroup Inc.
December 19, 2023
Page 2
decrease by 22.3%. Refer to Item 303 of Regulation S-K.
Form 8-K furnished October 19, 2023
Exhibit 99.1, page 1
2.You present a non-GAAP measure of Free Cash Flow in the initial bullet points of your
earnings release. Please revise to include the disclosures required by Item 10(e)(1)(i) of
Regulation S-K.
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 Robert Shapiro at 202-551-3273 or Abe Friedman at 202-551-8298 with
any questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services