SEC Comment Letter for GSK (GSK) — Aug 18, 2021
GSK plc
Date: Aug. 18, 2021 · CIK: 0001131399 · Accession: 0000000000-21-010168
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United States securities and exchange commission logo August 18, 2021 Iain Mackay Chief Financial Officer GlaxoSmithKline plc 980 Great West Road Brentford, Middlesex TW8 9GS England Re:GlaxoSmithKline plc Form 20-F for the fiscal year ended December 31, 2020 Filed March 12, 2021 File No. 1-15170 Dear Mr. Mackay: We have reviewed your filing and have the following comment. We may ask you to provide us with information so we may better understand your disclosure. Please respond to this 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 this comment, we may have additional comments. Form 20-F for the fiscal year December 31, 2020 Exhibit 15.2 - Annual Report Group financial review, page 50 Financial performance, page 55 1.We note in the Research and development section on page 60 that you do not quantify actual research and development expenditure by segment, only Adjusted R&D by segment. Given the materiality of these expenses, please address your consideration for apparently not continuing to provide this information given, among other things, the requirements of paragraph 21(b) of IFRS 8. 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.
FirstName LastNameIain Mackay Comapany NameGlaxoSmithKline plc August 18, 2021 Page 2 FirstName LastName Iain Mackay GlaxoSmithKline plc August 18, 2021 Page 2 You may contact Jenn Do at (202) 551-3743 or Daniel Gordon at (202) 551-3486 if you have any questions. Sincerely, Division of Corporation Finance Office of Life Sciences
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United States securities and exchange commission logo
August 18, 2021
Iain Mackay
Chief Financial Officer
GlaxoSmithKline plc
980 Great West Road
Brentford, Middlesex TW8 9GS
England
Re:GlaxoSmithKline plc
Form 20-F for the fiscal year ended December 31, 2020
Filed March 12, 2021
File No. 1-15170
Dear Mr. Mackay:
We have reviewed your filing and have the following comment. We may ask you to
provide us with information so we may better understand your disclosure.
Please respond to this 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 this comment, we may have additional comments.
Form 20-F for the fiscal year December 31, 2020
Exhibit 15.2 - Annual Report
Group financial review, page 50
Financial performance, page 55
1.We note in the Research and development section on page 60 that you do not quantify
actual research and development expenditure by segment, only Adjusted R&D by
segment. Given the materiality of these expenses, please address your consideration for
apparently not continuing to provide this information given, among other things, the
requirements of paragraph 21(b) of IFRS 8.
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.
FirstName LastNameIain Mackay
Comapany NameGlaxoSmithKline plc
August 18, 2021 Page 2
FirstName LastName
Iain Mackay
GlaxoSmithKline plc
August 18, 2021
Page 2
You may contact Jenn Do at (202) 551-3743 or Daniel Gordon at (202) 551-3486 if you
have any questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences