SEC Comment Letter 0000000000-24-001037 to RENTOKIL INITIAL PLC /FI (RTO, RKLIF) (CIK 0000930157) (RTO)
RENTOKIL INITIAL PLC /FI (RTO, RKLIF) (CIK 0000930157)
Date: Jan. 26, 2024 · CIK: 0000930157 · Accession: 0000000000-24-001037
AI Filing Summary & Sentiment
File numbers found in text: 001-41524
Letter
United States securities and exchange commission logo January 26, 2024 Stuart Ingall-Tombs Chief Financial Officer Rentokil Initial plc Compass House Manor Royal Crawley West Sussex RH10 9PY United Kingdom Re:Rentokil Initial plc Form 20-F for the Fiscal Year Ended December 31, 2022 Response Dated January 25, 2024 File No. 001-41524 Dear Stuart Ingall-Tombs: We have reviewed your January 25, 2024 response to our comment letter and have the following comment(s). 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 December 20, 2023 letter. Form 20-F for the Fiscal Year Ended December 31, 2022 Item 5. Operating and Financial Review Prospects, page 19 1.We read your response to prior comment 3. Please present and discuss operating cash flow to net income ratio, whenever adjusted free cash flow conversion is presented or discussed. Refer to Item 10(e)(1)(i)(A) of Regulation S-K, Regulation G and footnote 27 to SEC Release No. 33-8176.
FirstName LastNameStuart Ingall-Tombs Comapany NameRentokil Initial plc January 26, 2024 Page 2 FirstName LastName Stuart Ingall-Tombs Rentokil Initial plc January 26, 2024 Page 2
Please contact Keira Nakada at 202-551-3659 or Rufus Decker at 202-551-3769 if you have any questions. Sincerely, Division of Corporation Finance Office of Trade & Services
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United States securities and exchange commission logo
January 26, 2024
Stuart Ingall-Tombs
Chief Financial Officer
Rentokil Initial plc
Compass House
Manor Royal
Crawley
West Sussex RH10 9PY
United Kingdom
Re:Rentokil Initial plc
Form 20-F for the Fiscal Year Ended December 31, 2022
Response Dated January 25, 2024
File No. 001-41524
Dear Stuart Ingall-Tombs:
We have reviewed your January 25, 2024 response to our comment letter and have the
following comment(s).
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 December 20, 2023
letter.
Form 20-F for the Fiscal Year Ended December 31, 2022
Item 5. Operating and Financial Review Prospects, page 19
1.We read your response to prior comment 3. Please present and discuss operating cash flow
to net income ratio, whenever adjusted free cash flow conversion is presented or
discussed. Refer to Item 10(e)(1)(i)(A) of Regulation S-K, Regulation G and footnote 27
to SEC Release No. 33-8176.
FirstName LastNameStuart Ingall-Tombs
Comapany NameRentokil Initial plc
January 26, 2024 Page 2
FirstName LastName
Stuart Ingall-Tombs
Rentokil Initial plc
January 26, 2024
Page 2
Please contact Keira Nakada at 202-551-3659 or Rufus Decker at 202-551-3769 if you
have any questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services