SEC Comment Letter for HAIN CELESTIAL GROUP (HAIN) — Mar 23, 2020
HAIN CELESTIAL GROUP INC
Date: March 23, 2020 · CIK: 0000910406 · Accession: 0000000000-20-002531
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 000-22818
Letter
March 23, 2020 Javier H. Idrovo Chief Financial Officer Hain Celestial Group Inc. 1111 Marcus Avenue Lake Success, New York 11042 Re:Hain Celestial Group Inc. Form 10-K for the Year Ended June 30, 2019 Filed August 29, 2019 File No. 000-22818 Dear Mr. Idrovo: We have limited our review of your filing to the financial statements and related disclosures 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. Form 10-K for the Year Ended June 30, 2019 Reconciliation of Non-U.S. GAAP Financial Measures to U.S. GAAP Measures Adjusted EBITDA, page 48 1.We note that the subtotal labelled EBITDA in your reconciliation on page 49 reflects adjustments for items other than interest, taxes, depreciation and amortization. Please revise your presentations in future filings to use a title that clearly distinguishes these amounts from EBITDA, as described in Exchange Act Release No. 47226, or alternatively to present an EBITDA measure that is calculated consistent with that description. Refer to Question 103.01 of the Compliance and Disclosure Interpretations on Non-GAAP Measures. 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.
FirstName LastNameJavier H. Idrovo Comapany NameHain Celestial Group Inc. March 23, 2020 Page 2 FirstName LastName Javier H. Idrovo Hain Celestial Group Inc. March 23, 2020 Page 2 You may contact Ernest Greene, Staff Accountant, at 202-551-3733 or Martin James, Senior Advisor, at 202-551-3671 with any questions. Sincerely, Division of Corporation Finance Office of Manufacturing
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March 23, 2020
Javier H. Idrovo
Chief Financial Officer
Hain Celestial Group Inc.
1111 Marcus Avenue
Lake Success, New York 11042
Re:Hain Celestial Group Inc.
Form 10-K for the Year Ended June 30, 2019
Filed August 29, 2019
File No. 000-22818
Dear Mr. Idrovo:
We have limited our review of your filing to the financial statements and related
disclosures 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.
Form 10-K for the Year Ended June 30, 2019
Reconciliation of Non-U.S. GAAP Financial Measures to U.S. GAAP Measures
Adjusted EBITDA, page 48
1.We note that the subtotal labelled EBITDA in your reconciliation on page 49
reflects adjustments for items other than interest, taxes, depreciation and amortization.
Please revise your presentations in future filings to use a title that clearly distinguishes
these amounts from EBITDA, as described in Exchange Act Release No. 47226, or
alternatively to present an EBITDA measure that is calculated consistent with that
description. Refer to Question 103.01 of the Compliance and Disclosure Interpretations
on Non-GAAP Measures.
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.
FirstName LastNameJavier H. Idrovo
Comapany NameHain Celestial Group Inc.
March 23, 2020 Page 2
FirstName LastName
Javier H. Idrovo
Hain Celestial Group Inc.
March 23, 2020
Page 2
You may contact Ernest Greene, Staff Accountant, at 202-551-3733 or Martin James,
Senior Advisor, at 202-551-3671 with any questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing