Correspondence 0001193125-23-271378 from SINOPEC SHANGHAI PETROCHEMICAL CO LTD (SPTJF) (CIK 0000908732) (SPTJF)
SINOPEC SHANGHAI PETROCHEMICAL CO LTD (SPTJF) (CIK 0000908732)
Date: Nov. 6, 2023 · CIK: 0000908732 · Accession: 0001193125-23-271378
AI Filing Summary & Sentiment
File numbers found in text: 001-12158
Letter
VIA EDGAR United States Securities and Exchange Commission Division of Corporation Finance Re: Sinopec Shanghai Petrochemical Company Limited Form 20-F for Fiscal Year Ended December 31, 2022 Response Dated September 20, 2023 File No. 001-12158
Dear Messrs. Howes and Mew:
On behalf of Sinopec Shanghai Petrochemical Company Limited (the “Company”), this letter responds to your letter, dated October 5, 2023 (the “Comment Letter”), regarding the above-referenced filing on Form 20-F (the “Annual Report”). Each of your comments is set forth below, followed by the corresponding response. For ease of reference, the headings and numbered paragraphs below correspond to the headings and numbered comments in the Comment Letter. Each response of the Company is set forth in ordinary type beneath the corresponding comment of the Staff of the Division of Corporation Finance (the “Staff”) of the Securities and Exchange Commission (the “SEC”) from the Comment Letter appearing in bold type.
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.
November 6, 2023
Page Two
Response: The Company respectfully advises the Staff that information about the Company’s board members taking positions in the Party is as follows:
Name
Position in CCP Committee of the Company
Wan Tao
Secretary and Member of CCP Committee of the Company
Guan Zemin
Deputy Secretary and Member of CCP Committee of the Company
Du Jun
Member of CCP Committee of the Company
Huang Xiangyu
Member of CCP Committee of the Company
Except for the four directors named above, none of the seven other directors takes any position in the CCP Committee of the Company.
As stated on Page 85 of the Annual Report of the Company, some articles of the Company’s Articles of Association contain provisions relating to the CCP. The directors named above perform their responsibilities as members of CCP Committee of the Company in accordance with such provisions of the Company’s Articles of Association, and are not involved in the CCP’s making of any policy or decision.
In addition, the Company respectfully advises that Wan Tao no longer takes any position in Sinopec Yizheng Chemical Fibre Limited Liability Company.
* * *
If you require additional information or have any questions about this letter, please do not hesitate to contact me at SLesmes@mofo.com or (202) 887-1585.
Sincerely,
/s/ Scott Lesmes
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CORRESP 1 filename1.htm CORRESP 2100 L STREET, NW SUITE 900 WASHINGTON DC 20037 TELEPHONE: 202.887.1500 FACSIMILE: 202.887.0763 WWW.MOFO.COM MORRISON & FOERSTER LLP AUSTIN, BEIJING, BERLIN, BOSTON, BRUSSELS, DENVER, HONG KONG, LONDON, LOS ANGELES, MIAMI, NEW YORK, PALO ALTO, SAN DIEGO, SAN FRANCISCO, SHANGHAI, SINGAPORE, TOKYO, WASHINGTON, D.C. November 6, 2023 VIA EDGAR Tyler Howes Andrew Mew United States Securities and Exchange Commission Division of Corporation Finance 100 F Street N.E. Washington, D.C. 20549-7010 Re: Sinopec Shanghai Petrochemical Company Limited Form 20-F for Fiscal Year Ended December 31, 2022 Response Dated September 20, 2023 File No. 001-12158 Dear Messrs. Howes and Mew: On behalf of Sinopec Shanghai Petrochemical Company Limited (the “Company”), this letter responds to your letter, dated October 5, 2023 (the “Comment Letter”), regarding the above-referenced filing on Form 20-F (the “Annual Report”). Each of your comments is set forth below, followed by the corresponding response. For ease of reference, the headings and numbered paragraphs below correspond to the headings and numbered comments in the Comment Letter. Each response of the Company is set forth in ordinary type beneath the corresponding comment of the Staff of the Division of Corporation Finance (the “Staff”) of the Securities and Exchange Commission (the “SEC”) from the Comment Letter appearing in bold type. 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. November 6, 2023 Page Two Response: The Company respectfully advises the Staff that information about the Company’s board members taking positions in the Party is as follows: Name Position in CCP Committee of the Company Wan Tao Secretary and Member of CCP Committee of the Company Guan Zemin Deputy Secretary and Member of CCP Committee of the Company Du Jun Member of CCP Committee of the Company Huang Xiangyu Member of CCP Committee of the Company Except for the four directors named above, none of the seven other directors takes any position in the CCP Committee of the Company. As stated on Page 85 of the Annual Report of the Company, some articles of the Company’s Articles of Association contain provisions relating to the CCP. The directors named above perform their responsibilities as members of CCP Committee of the Company in accordance with such provisions of the Company’s Articles of Association, and are not involved in the CCP’s making of any policy or decision. In addition, the Company respectfully advises that Wan Tao no longer takes any position in Sinopec Yizheng Chemical Fibre Limited Liability Company. * * * If you require additional information or have any questions about this letter, please do not hesitate to contact me at SLesmes@mofo.com or (202) 887-1585. Sincerely, /s/ Scott Lesmes Scott Lesmes Cc: Du Jun, Chief Financial Officer Sinopec Shanghai Petrochemical Company Limited