SEC Comment Letter 0000000000-23-009082 to SINOPEC SHANGHAI PETROCHEMICAL CO LTD (SPTJF) (CIK 0000908732) (SPTJF)
SINOPEC SHANGHAI PETROCHEMICAL CO LTD (SPTJF) (CIK 0000908732)
Date: Aug. 21, 2023 · CIK: 0000908732 · Accession: 0000000000-23-009082
AI Filing Summary & Sentiment
File numbers found in text: 001-12158
Letter
United States securities and exchange commission logo August 21, 2023 Jun Du Chief Financial Officer Sinopec Shanghai Petrochemical Company Limited No. 48 Jinyi Road Jinshan District, Shanghai, 200540 People’s Republic of China Re:Sinopec Shanghai Petrochemical Company Limited Form 20-F for the Fiscal Year Ended December 31, 2022 File No. 001-12158 Dear Jun Du: We have limited our review of your filing to the submission and/or disclosures as required by Item 16I of Form 20-F and have the following comments. In some of our comments, we may ask you to provide us with information so we may better understand your disclosure. Please respond to these comments within ten business days by providing the requested information or advise us as soon as possible when you will respond. After reviewing your response to these comments, we may have additional comments. Form 20-F for the Fiscal Year Ended December 31, 2022 Item 16I. Disclosure Regarding Foreign Jurisdictions that Prevent Inspections, page 85 1.Please supplementally describe any additional materials that were reviewed and tell us whether you relied upon any legal opinions or third party certifications such as affidavits as the basis for your submission. In your response, please provide a similarly detailed discussion of the materials reviewed and legal opinions or third party certifications relied upon in connection with the required disclosures under paragraphs (b)(2) and (3). 2.In order to clarify the scope of your review, please supplementally describe the steps you have taken to confirm that none of the members of your board or the boards of your consolidated foreign operating entities are officials of the Chinese Communist Party. For instance, please tell us how the board members’ current or prior memberships on, or affiliations with, committees of the Chinese Communist Party factored into your determination. In addition, please tell us whether you have relied upon third party certifications such as affidavits as the basis for your disclosure.
FirstName LastNameJun Du Comapany NameSinopec Shanghai Petrochemical Company Limited August 21, 2023 Page 2 FirstName LastName Jun Du Sinopec Shanghai Petrochemical Company Limited August 21, 2023 Page 2 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 Tyler Howes at 202-551-3370 or Andrew Mew at 202-551-3377 with any questions. Sincerely, Division of Corporation Finance Disclosure Review Program cc: Scott Lesmes, Esq.
Show Raw Text
United States securities and exchange commission logo
August 21, 2023
Jun Du
Chief Financial Officer
Sinopec Shanghai Petrochemical Company Limited
No. 48 Jinyi Road
Jinshan District, Shanghai, 200540
People’s Republic of China
Re:Sinopec Shanghai Petrochemical Company Limited
Form 20-F for the Fiscal Year Ended December 31, 2022
File No. 001-12158
Dear Jun Du:
We have limited our review of your filing to the submission and/or disclosures as
required by Item 16I of Form 20-F and have the following comments. In some of our comments,
we may ask you to provide us with information so we may better understand your disclosure.
Please respond to these comments within ten business days by providing the requested
information or advise us as soon as possible when you will respond.
After reviewing your response to these comments, we may have additional comments.
Form 20-F for the Fiscal Year Ended December 31, 2022
Item 16I. Disclosure Regarding Foreign Jurisdictions that Prevent Inspections, page 85
1.Please supplementally describe any additional materials that were reviewed and tell us
whether you relied upon any legal opinions or third party certifications such as affidavits
as the basis for your submission. In your response, please provide a similarly detailed
discussion of the materials reviewed and legal opinions or third party certifications relied
upon in connection with the required disclosures under paragraphs (b)(2) and (3).
2.In order to clarify the scope of your review, please supplementally describe the steps you
have taken to confirm that none of the members of your board or the boards of your
consolidated foreign operating entities are officials of the Chinese Communist Party. For
instance, please tell us how the board members’ current or prior memberships on, or
affiliations with, committees of the Chinese Communist Party factored into your
determination. In addition, please tell us whether you have relied upon third party
certifications such as affidavits as the basis for your disclosure.
FirstName LastNameJun Du
Comapany NameSinopec Shanghai Petrochemical Company Limited
August 21, 2023 Page 2
FirstName LastName
Jun Du
Sinopec Shanghai Petrochemical Company Limited
August 21, 2023
Page 2
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 Tyler Howes at 202-551-3370 or Andrew Mew at 202-551-3377 with any
questions.
Sincerely,
Division of Corporation Finance
Disclosure Review Program
cc: Scott Lesmes, Esq.