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Correspondence 0000910406-24-000046 from HAIN CELESTIAL GROUP INC (HAIN)

HAIN CELESTIAL GROUP INC
Date: June 26, 2024 · CIK: 0000910406 · Accession: 0000910406-24-000046

Financial Reporting Regulatory Compliance Revenue Recognition

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File numbers found in text: 000-22818

Referenced dates: June 12, 2024

Date
June 26, 2024
Author
/s/ Lee A. Boyce
Form
CORRESP
Company
HAIN CELESTIAL GROUP INC

Letter

VIA EDGAR United States Securities and Exchange Commission Division of Corporation Finance Office of Manufacturing Re: The Hain Celestial Group, Inc. Form 10-K for the Fiscal Year Ended June 30, 2023 Filed August 24, 2023 File No. 000-22818

Dear Ms. McConnell and Mr. James:

The Hain Celestial Group, Inc. (hereinafter referred to as the “Company,” “Hain Celestial” or “we”) submits this letter in response to the comment contained in the letter from the staff of the Division of Corporation Finance (the “Staff”) of the U.S. Securities and Exchange Commission dated June 12, 2024, regarding the above referenced filing and has provided the below response. For ease of reference, we have repeated the text of the Staff’s comment prior to our response.

Form 10-K for the Fiscal Year Ended June 30, 2023

Management's Discussion and Analysis of Financial Condition and Results of Operations Reconciliation of Non U.S. GAAP Financial Measures to U.S. GAAP Financial Measures, page 34

Staff Comment

1.We have considered your response to prior comment 1. We believe that decisions about the timing, method, and pricing of dispositions of inventory are normal, recurring activities integral to the management of an ongoing business. Please confirm to us you will no longer exclude inventory write-downs from your non-GAAP financial measures.

Hain Celestial Response

The Company acknowledges the Staff’s comment and confirms that it will no longer exclude inventory write-downs from its non-GAAP financial measures.

* * *

The Company acknowledges that the Company and its management are responsible for the adequacy and accuracy of the disclosures in the filing, notwithstanding any review, comments, action or absence of action by the Staff. If you have any questions regarding these responses or other issues relating to this correspondence, please contact me at (631) 719-3633 or lee.boyce@hain.com.

Sincerely,
/s/ Lee A. Boyce

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CORRESP
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Document

June 26, 2024

VIA EDGAR

United States Securities and Exchange Commission

Division of Corporation Finance

Office of Manufacturing

100 F Street, N.E.

Washington, D.C. 20549

Attn:    Anne McConnell

Martin James

Re:    The Hain Celestial Group, Inc.

Form 10-K for the Fiscal Year Ended June 30, 2023

Filed August 24, 2023

File No. 000-22818

Dear Ms. McConnell and Mr. James:

The Hain Celestial Group, Inc. (hereinafter referred to as the “Company,” “Hain Celestial” or “we”) submits this letter in response to the comment contained in the letter from the staff of the Division of Corporation Finance (the “Staff”) of the U.S. Securities and Exchange Commission dated June 12, 2024, regarding the above referenced filing and has provided the below response. For ease of reference, we have repeated the text of the Staff’s comment prior to our response.

Form 10-K for the Fiscal Year Ended June 30, 2023

Management's Discussion and Analysis of Financial Condition and Results of Operations
Reconciliation of Non U.S. GAAP Financial Measures to U.S. GAAP Financial Measures, page 34

Staff Comment

1.We have considered your response to prior comment 1. We believe that decisions about the timing, method, and pricing of dispositions of inventory are normal, recurring activities integral to the management of an ongoing business. Please confirm to us you will no longer exclude inventory write-downs from your non-GAAP financial measures.

Hain Celestial Response

The Company acknowledges the Staff’s comment and confirms that it will no longer exclude inventory write-downs from its non-GAAP financial measures.

*  *  *

The Company acknowledges that the Company and its management are responsible for the adequacy and accuracy of the disclosures in the filing, notwithstanding any review, comments, action or absence of action by the Staff. If you have any questions regarding these responses or other issues relating to this correspondence, please contact me at (631) 719-3633 or lee.boyce@hain.com.

Sincerely,

/s/ Lee A. Boyce

Lee A. Boyce
Executive Vice President and Chief Financial Officer

cc:          Kristy M. Meringolo, Chief Legal and Corporate Affairs Officer

Michael J. Ragusa, Senior Vice President and Chief Accounting Officer