Correspondence 0001104659-23-113965 from CHINA PETROLEUM & CHEMICAL CORP (SNPMF) (CIK 0001123658) (SNPMF)
CHINA PETROLEUM & CHEMICAL CORP (SNPMF) (CIK 0001123658)
Date: Nov. 3, 2023 · CIK: 0001123658 · Accession: 0001104659-23-113965
AI Filing Summary & Sentiment
File numbers found in text: 001-15138
Referenced dates: October 20, 2023
Letter
VIA EDGAR Division of Corporation Finance Securities and Exchange Commission Re: China Petroleum & Chemical Corporation Form 20-F for Fiscal Year Ended December 31, 2022 Response dated October 13, 2023 (the “Second Response Letter”) File No. 001-15138
Dear Mr. Dunham and Mr. Mew:
We refer to the letter dated October 20, 2023 from the staff (the “Staff”) of the United States Securities and Exchange Commission (the “Commission”) with respect to certain comments regarding the annual report on Form 20-F of China Petroleum & Chemical Corporation (the “Company”) for the fiscal year ended December 31, 2022 filed with the Commission on April 28, 2023 (the “2022 Form 20-F”). Set forth below are our responses to the Staff’s comments. For your convenience, we have also restated the Staff’s comments below in bold.
* * *
Form 20-F for Fiscal Year Ended December 31, 2022
Item 16I. Disclosure Regarding Foreign Jurisdictions that Prevent Inspections, page 99
1. In your amended Form 20-F, please also revise this section to disclose the ownership of your principal subsidiaries by “Other Entities Controlled by PRC Governmental Entities,” consistent with your response to comment 1. In this regard we note that Note 39 combines such entities with Other Entities not controlled by PRC governmental entities, disclosing all non-controlling interests in aggregate.
The Company respectfully submits that it will file an amendment to the 2022 Form 20-F to incorporate the disclosure on the ownership of its principal subsidiaries by “Other Entities Controlled by PRC Governmental Entities,” consistent with its response to Comment No. 1 as set forth in the Second Response Letter.
* * *
Please contact Alpine Wu, at (832) 834-2431 or alpinewu@sinopec.com if you have any questions. Thank you very much.
Sincerely,
China Petroleum & Chemical Corporation
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China Petroleum & Chemical Corporation
22 Chaoyangmen North Street
Chaoyang District, Beijing, 100728
The People’s Republic of China
November 3,
2023
VIA EDGAR
Mr. Christopher Dunham
Mr. Andrew Mew
Division of Corporation Finance
Disclosure Review Program
Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
Re:
China Petroleum & Chemical Corporation
Form 20-F for Fiscal Year Ended December 31, 2022
Response dated October 13, 2023 (the “Second Response
Letter”)
File No. 001-15138
Dear Mr. Dunham
and Mr. Mew:
We refer to the letter dated October 20, 2023 from
the staff (the “Staff”) of the United States Securities and Exchange Commission (the “Commission”) with
respect to certain comments regarding the annual report on Form 20-F of China Petroleum & Chemical Corporation (the “Company”)
for the fiscal year ended December 31, 2022 filed with the Commission on April 28, 2023 (the “2022 Form 20-F”). Set
forth below are our responses to the Staff’s comments. For your convenience, we have also restated the Staff’s comments
below in bold.
* * *
Form 20-F for Fiscal Year Ended December 31, 2022
Item 16I. Disclosure Regarding Foreign Jurisdictions that Prevent
Inspections, page 99
1. In your amended Form 20-F, please also revise this section to disclose the ownership of your principal subsidiaries by “Other
Entities Controlled by PRC Governmental Entities,” consistent with your response to comment 1. In this regard we note that Note
39 combines such entities with Other Entities not controlled by PRC governmental entities, disclosing all non-controlling interests in
aggregate.
The Company respectfully submits that it will file an amendment
to the 2022 Form 20-F to incorporate the disclosure on the ownership of its principal subsidiaries by “Other Entities Controlled
by PRC Governmental Entities,” consistent with its response to Comment No. 1 as set forth in the Second Response Letter.
* * *
Please
contact Alpine Wu, at (832) 834-2431 or alpinewu@sinopec.com if you have any questions. Thank you very much.
Sincerely,
China Petroleum & Chemical Corporation
By:
/s/
Huang Wensheng
Name:
Huang Wensheng
Title:
Vice President and Secretary to the Board of Directors