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apwc-responses_0705

   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    File No. 001-37928     Ladies and Gentlemen:     On behalf of Asia Pacific Wire & Cable Corporation Limited (the “Company”),  we are hereby filing with the Staff (the “Staff”) of the Division of Corporation Finance  of the Securities and Exchange Commission (the “Commission”) this response to the  letter dated June 10, 2024 from Heather Clark and Melissa Gilmore the Staff Office of  Manufacturing to Ivan Hsia the Company’s Chief Financial Officer (the “Comment  Letter”), with respect to the Company’s above-captioned Form 20-F for the Fiscal Year  Ended December 31, 2023 (the “Form 20-F”).     The comment and response set forth below are keyed to the headings used in the  Comment Letter.     Comment:  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 remove this apparent non-IFRS measure from your financial statement footnotes.  Refer to Item 10(e)(1)(ii)(C) of Regulation S-K.    Response to Comment:  The Company respectfully advises the Staff that the Company will in future  filings provide additional disclosure regarding the reference and definition of “net debt” and  “gearing ratio”, please see the underlined text that follows below.  “IAS 1.134-135  requires entities to make qualitative and quantitative disclosures regarding their  objectives, policies, and processes for managing capital. The Company has disclosed  its gearing ratio as this is the measure it uses to monitor capital. The Company  considers both capital and net debt as relevant components of funding, and hence,

part of its capital management. The gearing ratio indicates the current proportion of  debt in the Company's capital structure.  The Company has provided the definition of 'net debt' because this is relevant  to understanding how it manages capital, and it is not defined in the IFRS Accounting  Standard. Additionally, the Company has provided reconciliations between these  measures and items represented in the consolidated financial statements.”    27(d)    Capital management  The primary objectives of our Company’s capital management are to safeguard  our Company’s ability to continue as a going concern and maintain healthy capital  ratios in order to support its business, maximize shareholders’ value and to maintain  an optimal capital structure to reduce the cost of capital.  Our Company manages its capital structure and makes adjustments to it, in  light of changes in economic conditions and the risks characteristics of the underlying  assets. To maintain or adjust the capital structure, our Company may adjust the  dividend payment to shareholders, return capital to shareholders, issue new shares or  conduct stock repurchase programs. Our Company is not subject to any externally  imposed capital requirements. No changes were made in the objectives, policies or  processes for managing capital during the years ended December 31, 2023 and 2022.  In line with industry practices, our Company monitors capital on the basis of  the following gearing ratio:  Net debt (interest bearing loans and borrowings, trade and other payables, less  cash and cash equivalents, as shown in the Consolidated Balance Sheets.)  divided by   Total equity (as shown in the Consolidated Balance Sheets)    In addition, the Company acknowledges 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.      If you have any questions or comments regarding the foregoing, kindly contact  the undersigned at +886-2-27122558 or Paul Weber, our legal counsel, at +1(972)754- 8992.     Sincerely,     /s/ Ivan Hsia  Ivan Hsia   Chief Financial Officer