SEC Comment Letter 0000000000-23-003994 to SCHNITZER STEEL INDUSTRIES, INC. (RDUS) (CIK 0000912603)
SCHNITZER STEEL INDUSTRIES, INC. (RDUS) (CIK 0000912603)
Date: April 20, 2023 · CIK: 0000912603 · Accession: 0000000000-23-003994
AI Filing Summary & Sentiment
File numbers found in text: 000-22496
Letter
United States securities and exchange commission logo April 20, 2023 Stefano Gaggini Senior Vice President and Chief Financial Officer Schnitzer Steel Industries, Inc. 299 SW Clay Street, Suite 350 Portland, OR 97201 Re:Schnitzer Steel Industries, Inc. Form 10-K for the Fiscal Year Ended August 31, 2022 Filed October 24, 2022 File No. 000-22496 Dear Stefano Gaggini: We have reviewed your April 14, 2023 response to our comment letter 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 the 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 the comment, we may have additional comments. Unless we note otherwise, our reference to prior comment to comments in our March 31, 2023 letter. Form 10-K for the Fiscal Year Ended August 31, 2022 Management's Discussion and Analysis of Financial Condition and Results of Operations Non-GAAP Financial Measures, page 51 1.We note your response to comment 1. Since you are adjusting your various Non-GAAP measures for changes in legal and environmental charges, net of recoveries, for legacy environmental matters, please tell us how you considered the guidance in Question 100.04 of the Compliance and Disclosure Interpretations Regarding Non-GAAP measures in determining that the inclusion of these adjustments is appropriate. Please note that Question 100.04 indicates that changing the basis of accounting for revenues and expenses in a Non-GAAP performance measure from an accrual basis would not be appropriate.
FirstName LastNameStefano Gaggini Comapany NameSchnitzer Steel Industries, Inc. April 20, 2023 Page 2 FirstName LastName Stefano Gaggini Schnitzer Steel Industries, Inc. April 20, 2023 Page 2
You may contact Keira Nakada at 202-551-3659 or Linda Cvrkel at 202-551-3813 with any questions. Sincerely, Division of Corporation Finance Office of Trade & Services
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United States securities and exchange commission logo
April 20, 2023
Stefano Gaggini
Senior Vice President and Chief Financial Officer
Schnitzer Steel Industries, Inc.
299 SW Clay Street, Suite 350
Portland, OR 97201
Re:Schnitzer Steel Industries, Inc.
Form 10-K for the Fiscal Year Ended August 31, 2022
Filed October 24, 2022
File No. 000-22496
Dear Stefano Gaggini:
We have reviewed your April 14, 2023 response to our comment letter 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 the 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 the comment, we may have additional
comments. Unless we note otherwise, our reference to prior comment to comments in our March
31, 2023 letter.
Form 10-K for the Fiscal Year Ended August 31, 2022
Management's Discussion and Analysis of Financial Condition and Results of Operations
Non-GAAP Financial Measures, page 51
1.We note your response to comment 1. Since you are adjusting your various Non-GAAP
measures for changes in legal and environmental charges, net of recoveries, for legacy
environmental matters, please tell us how you considered the guidance in Question 100.04
of the Compliance and Disclosure Interpretations Regarding Non-GAAP measures in
determining that the inclusion of these adjustments is appropriate. Please note that
Question 100.04 indicates that changing the basis of accounting for revenues and expenses
in a Non-GAAP performance measure from an accrual basis would not be appropriate.
FirstName LastNameStefano Gaggini
Comapany NameSchnitzer Steel Industries, Inc.
April 20, 2023 Page 2
FirstName LastName
Stefano Gaggini
Schnitzer Steel Industries, Inc.
April 20, 2023
Page 2
You may contact Keira Nakada at 202-551-3659 or Linda Cvrkel at 202-551-3813 with
any questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services