SEC Comment Letter 0000000000-24-006616 to ASIA PACIFIC WIRE & CABLE CORP LTD (APWC)
ASIA PACIFIC WIRE & CABLE CORP LTD
Date: June 10, 2024 · CIK: 0001026980 · Accession: 0000000000-24-006616
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 001-14542
Letter
United States securities and exchange commission logo June 10, 2024 Ivan Hsia Chief Financial Officer Asia Pacific Wire & Cable Corporation Limited 15/Fl. B, No. 77, Sec. 2 Dunhua South Road Taipei, 106, Taiwan Republic of China Re:Asia Pacific Wire & Cable Corporation Limited Form 20-F for the Year Ended December 31, 2023 Filed April 29, 2024 File No. 001-14542 Dear Ivan Hsia: We have limited our review of your filing to the financial statements and related disclosures 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. Form 20-F for the Year Ended December 31, 2023 Financial Statements Notes to the Consolidated Financial Statements 27. Financial Risk Management Objectives 27(d) Capital management, page F-84 1.We refer to “net debt” and “gearing ratio.” Please tell us whether these measures are currently required to be disclosed by your home country or other applicable securities regulators. If these measures are not currently required to be disclosed by IFRS, Commission Rules, or regulatory requirements, it appears that they are non- IFRS measures as defined by Item 10(e)(2) in Regulation S-K. Therefore, please expand your disclosure in your future filings to explain how it was calculated, and provide reconciliation to the most directly comparable IFRS measure. Refer to General Instruction C(e) of Form 20-F. To the extent this is not required by IFRS, please revise to
FirstName LastNameIvan Hsia Comapany NameAsia Pacific Wire & Cable Corporation Limited June 10, 2024 Page 2 FirstName LastName Ivan Hsia Asia Pacific Wire & Cable Corporation Limited June 10, 2024 Page 2 remove this apparent non-IFRS measure from your financial statement footnotes. Refer to Item 10(e)(1)(ii)(C) of Regulation S-K.
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. Please contact Heather Clark at 202-551-3624 or Melissa Gilmore at 202-551-3777 with any questions. Sincerely, Division of Corporation Finance Office of Manufacturing
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United States securities and exchange commission logo
June 10, 2024
Ivan Hsia
Chief Financial Officer
Asia Pacific Wire & Cable Corporation Limited
15/Fl. B, No. 77, Sec. 2
Dunhua South Road
Taipei, 106, Taiwan
Republic of China
Re:Asia Pacific Wire & Cable Corporation Limited
Form 20-F for the Year Ended December 31, 2023
Filed April 29, 2024
File No. 001-14542
Dear Ivan Hsia:
We have limited our review of your filing to the financial statements and related
disclosures 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.
Form 20-F for the Year Ended December 31, 2023
Financial Statements
Notes to the Consolidated Financial Statements
27. Financial Risk Management Objectives
27(d) Capital management, page F-84
1.We refer to “net debt” and “gearing ratio.” Please tell us whether these measures are
currently required to be disclosed by your home country or other applicable securities
regulators. If these measures are not currently required to be disclosed by IFRS,
Commission Rules, or regulatory requirements, it appears that they are non-
IFRS measures as defined by Item 10(e)(2) in Regulation S-K. Therefore, please expand
your disclosure in your future filings to explain how it was calculated, and provide
reconciliation to the most directly comparable IFRS measure. Refer to General
Instruction C(e) of Form 20-F. To the extent this is not required by IFRS, please revise to
FirstName LastNameIvan Hsia
Comapany NameAsia Pacific Wire & Cable Corporation Limited
June 10, 2024 Page 2
FirstName LastName
Ivan Hsia
Asia Pacific Wire & Cable Corporation Limited
June 10, 2024
Page 2
remove this apparent non-IFRS measure from your financial statement footnotes. Refer to
Item 10(e)(1)(ii)(C) of Regulation S-K.
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.
Please contact Heather Clark at 202-551-3624 or Melissa Gilmore at 202-551-3777 with
any questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing