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August 4, 2023
Zhu Runzhou
Chief Executive Officer
Aluminum Corporation of China Limited
No. 62 North Xizhimen Street, Haidian District, Beijing
People’s Republic of China ( 100082 )
Re:Aluminum Corporation of China Limited
Form 20-F for the Fiscal Year Ended December 31, 2022
File No. 001-15264
Dear Zhu Runzhou:
            We have limited our review of your filing to the submission and/or disclosures as
required by Item 16I of Form 20-F and have the following comments.  In some of our comments,
we may ask you to provide us with information so we may better understand your disclosure.
            Please respond to these comments within ten business days by providing the requested
information or advise us as soon as possible when you will respond.
            After reviewing your response to these comments, we may have additional comments.
Form 20-F for the Fiscal Year Ended December 31, 2022
Item 16I. Disclosure Regarding Foreign Jurisdictions that Prevent Inspections, page 139
1.We note your disclosures on pages iii, iv, vi, and 139.  Please confirm, if true, that you are
controlled by the State-owned Assets Supervision and Administration Commission of the
State Council of China by virtue of the SASAC’s total ownership of your controlling
shareholder.  Please also briefly explain the State Council of China and the SASAC’s role
as governmental entities.

 FirstName LastNameZhu Runzhou
 Comapany NameAluminum Corporation of China Limited
 August 4, 2023 Page 2
 FirstName LastName
Zhu Runzhou
Aluminum Corporation of China Limited
August 4, 2023
Page 2
2.We note that your principal subsidiaries provided in Note 1 to your consolidated financial
statements indicates that you have a subsidiary in Hong Kong.  Please note that Item
16I(b) requires that you provide disclosures for yourself and all of your consolidated
foreign operating entities, including variable interest entities or similar structures.

•With respect to (b)(2), please supplementally clarify the jurisdictions in which your
consolidated foreign operating entities are organized or incorporated and provide the
percentage of your shares or the shares of your consolidated operating entities owned
by governmental entities in each foreign jurisdiction in which you have consolidated
operating entities in your supplemental response.
•With respect to (b)(3), (b)(4), and (b)(5), please provide the required information for
you and all of your consolidated foreign operating entities in your supplemental
response.
3.Please supplementally describe the materials that were reviewed and tell us whether you
relied upon any legal opinions or third party certifications such as affidavits as the basis
for your disclosure under paragraphs (b)(2) and (3).
4.We note your disclosure at page 139 that eight of your directors are “members of the
Chinese Communist Party.”  Please further identify each “official” of the Chinese
Communist Party as required by Item 16I(b)(4) of the Form 20-F.
5.In order to clarify the scope of your review, please supplementally describe the steps you
have taken to identify whether the members of your board or the boards of your
consolidated foreign operating entities are officials of the Chinese Communist Party.  For
instance, please tell us how the board members’ current or prior memberships on, or
affiliations with, committees of the Chinese Communist Party factored into your
determination.  In addition, please tell us whether you have relied upon third party
certifications such as affidavits as the basis for your disclosure.
6.With respect to your disclosure pursuant to Item 16I(b)(5), please confirm that your
Articles of Association contain one or more charters of the Chinese Communist Party, or
the text of any such charters, and tell us the text of such charters.  We also note that you
have included language that such disclosure is “to our best knowledge.”  Please
supplementally confirm without qualification, if true, that your articles and the articles of
your consolidated foreign operating entities do not contain wording from any charter of
the Chinese Communist Party other than those outlined in your response.

 FirstName LastNameZhu Runzhou
 Comapany NameAluminum Corporation of China Limited
 August 4, 2023 Page 3
 FirstName LastName
Zhu Runzhou
Aluminum Corporation of China Limited
August 4, 2023
Page 3
            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 Kyle Wiley at (202) 344-5791 or Christopher Dunham at (202) 551-3783
with any questions.
Sincerely,
Division of Corporation Finance
Disclosure Review Program
cc:       Chin-Yang Lin