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December 26, 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
Response dated November 17, 2023
File No. 001-15264
Dear Zhu Runzhou:
            We have reviewed your November 17, 2023 response to our comment letter and have the
following comments.
            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. Unless
we note otherwise, any references to prior comments are to comments in our October 19, 2023
letter.
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 response to comment 1 indicates that a "Chinese governmental entity has a
controlling financial interest in the Company and each such wholly-owned subsidiary," as
well as in all 14 of your partially-owned subsidiaries, either through you or other entities
controlled by Chinese government entities. Please revise your annual report consistent
with your response, quantifying 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.
2.We note that you do not believe that any members of your board of directors or your
supervisors, including those who are members or officials of the Communist Party
Committees of Aluminum Corporation of China or Chinalco, are Chinese Communist
Party officials. Please clarify the basis for this statement given that Article 33 of the

 FirstName LastNameZhu Runzhou
 Comapany NameAluminum Corporation of China Limited
 December 26, 2023 Page 2
 FirstName LastName
Zhu Runzhou
Aluminum Corporation of China Limited
December 26, 2023
Page 2
Chinese Communist Party Constitution addresses the leading Party members groups or
Party committees of state-owned enterprises, indicating they should play a leadership role
and discuss and decide on major issues of their enterprise in accordance with regulations.
In your response, please address the following:

•Please explain to us in reasonable detail the roles and responsibilities of the
Communist Party Committees of Aluminum Corporation of China and Chinalco,
including how they participate in deciding the major issues of their enterprise and the
extent to which this group approves and directs the major decisions and activities of
their enterprise.

•Please provide us with a detailed explanation of the roles and responsibilities of each
of your directors or supervisors who is also an official or member of the Communist
Party Committees of Aluminum Corporation of China or Chinalco on
Chalco's operations and major decisions.

•Please explain to us in more detail how you considered whether the Communist Party
Committees of Aluminum Corporation of China or Chinalco has effectively been
appointed by or is effectively acting as an agent for the Chinese Communist Party
and whether the functions of this role would reasonably meet a definition of a
Chinese Communist Party official.
            Please contact Christopher Dunham at 202-551-3783 or Andrew Mew at 202-551-3377
with any questions.
Sincerely,
Division of Corporation Finance
Disclosure Review Program
cc:       Chin-Yang Lin