SEC Comment Letter 0000000000-23-011014 to SINOPEC SHANGHAI PETROCHEMICAL CO LTD (SPTJF) (CIK 0000908732) (SPTJF)
SINOPEC SHANGHAI PETROCHEMICAL CO LTD (SPTJF) (CIK 0000908732)
Date: Oct. 5, 2023 · CIK: 0000908732 · Accession: 0000000000-23-011014
AI Filing Summary & Sentiment
File numbers found in text: 001-12158
Letter
United States securities and exchange commission logo October 5, 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 Response dated September 20, 2023 File No. 001-12158 Dear Jun Du: We have reviewed your September 20, 2023 response to our comment letter and have the following comment. 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 August 21, 2023 letter. Form 20-F for the Fiscal Year Ended December 31, 2022 Item 16I. Disclosure Regarding Foreign Jurisdictions that Prevent Inspections, page 85 1.We note your response to prior comment 2 including your statement that certain directors are members of the Party Committee of the Company. Please provide us with your analysis with respect to each of your directors, including whether such directors have any involvement in CCP matters, including your consideration of current and prior CCP memberships or affiliations with the CCP and their respective roles and responsibilities. For example, we note from Item 6 that Wan Tao served as deputy secretary of the CPC Committee of Sinopec Yizheng Chemical Fibre Limited Liability Company. Please contact Tyler Howes at 202-551-3370 or Andrew Mew at 202-551-3377 with any questions.
FirstName LastNameJun Du Comapany NameSinopec Shanghai Petrochemical Company Limited October 5, 2023 Page 2 FirstName LastName Jun Du Sinopec Shanghai Petrochemical Company Limited October 5, 2023 Page 2 Sincerely, Division of Corporation Finance Disclosure Review Program cc: Scott Lesmes, Esq.
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United States securities and exchange commission logo
October 5, 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
Response dated September 20, 2023
File No. 001-12158
Dear Jun Du:
We have reviewed your September 20, 2023 response to our comment letter and have the
following comment.
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 August 21, 2023
letter.
Form 20-F for the Fiscal Year Ended December 31, 2022
Item 16I. Disclosure Regarding Foreign Jurisdictions that Prevent Inspections, page 85
1.We note your response to prior comment 2 including your statement that certain directors
are members of the Party Committee of the Company. Please provide us with your
analysis with respect to each of your directors, including whether such directors have any
involvement in CCP matters, including your consideration of current and prior CCP
memberships or affiliations with the CCP and their respective roles and responsibilities.
For example, we note from Item 6 that Wan Tao served as deputy secretary of the CPC
Committee of Sinopec Yizheng Chemical Fibre Limited Liability Company.
Please contact Tyler Howes at 202-551-3370 or Andrew Mew at 202-551-3377 with any
questions.
FirstName LastNameJun Du
Comapany NameSinopec Shanghai Petrochemical Company Limited
October 5, 2023 Page 2
FirstName LastName
Jun Du
Sinopec Shanghai Petrochemical Company Limited
October 5, 2023
Page 2
Sincerely,
Division of Corporation Finance
Disclosure Review Program
cc: Scott Lesmes, Esq.