SEC Comment Letter for Novelis Inc. (CIK 0001304280) — Feb 3, 2022
Novelis Inc. (CIK 0001304280)
Date: Feb. 3, 2022 · CIK: 0001304280 · Accession: 0000000000-22-001395
AI Filing Summary & Sentiment
File numbers found in text: 001-32312
Letter
United States securities and exchange commission logo February 3, 2022 Devinder Ahuja Chief Financial Officer Novelis Inc. 3560 Lenox Road, Suite 2000 Atlanta, Georgia 30326 Re:Novelis Inc. Form 10-K for the Fiscal Year Ended March 31, 2021 Filed May 12, 2021 File No. 001-32312 Dear Mr. Ahuja: We have limited our review of your filing to the financial statements and related disclosures and have the following comment. In our 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 10-K for the Fiscal Year Ended March 31, 2021 Managements Discussion and Analysis of Financial Condition and Results of Operations Liquidity and Capital Resources Free Cash Flow, page 36 1.We note your non-GAAP measure of free cash flow on page 36. Please be advised that free cash flow is typically calculated as cash flow from operating activities less capital expenditures. As your free cash flow measure is calculated differently and consists of other items, revise the title of the measure to distinguish it from free cash flow, such as adjusted free cash flow, to avoid confusion. Refer to Question No. 102.07 of the C&DI on Non-GAAP Financial Measures. Similarly revise the title of free cash flow in your Form 10-Qs, earnings releases and elsewhere as appropriate. In closing, 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
FirstName LastNameDevinder Ahuja Comapany NameNovelis Inc. February 3, 2022 Page 2 FirstName LastName Devinder Ahuja Novelis Inc. February 3, 2022 Page 2 absence of action by the staff. You may contact Heather Clark at 202-551-3624 or Jean Yu at 202-551-3305 with any questions. Sincerely, Division of Corporation Finance Office of Manufacturing
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United States securities and exchange commission logo
February 3, 2022
Devinder Ahuja
Chief Financial Officer
Novelis Inc.
3560 Lenox Road, Suite 2000
Atlanta, Georgia 30326
Re:Novelis Inc.
Form 10-K for the Fiscal Year Ended March 31, 2021
Filed May 12, 2021
File No. 001-32312
Dear Mr. Ahuja:
We have limited our review of your filing to the financial statements and related
disclosures and have the following comment. In our 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 10-K for the Fiscal Year Ended March 31, 2021
Managements Discussion and Analysis of Financial Condition and Results of Operations
Liquidity and Capital Resources
Free Cash Flow, page 36
1.We note your non-GAAP measure of free cash flow on page 36. Please be advised that
free cash flow is typically calculated as cash flow from operating activities less capital
expenditures. As your free cash flow measure is calculated differently and consists of
other items, revise the title of the measure to distinguish it from free cash flow, such as
adjusted free cash flow, to avoid confusion. Refer to Question No. 102.07 of the C&DI on
Non-GAAP Financial Measures. Similarly revise the title of free cash flow in your
Form 10-Qs, earnings releases and elsewhere as appropriate.
In closing, 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
FirstName LastNameDevinder Ahuja
Comapany NameNovelis Inc.
February 3, 2022 Page 2
FirstName LastName
Devinder Ahuja
Novelis Inc.
February 3, 2022
Page 2
absence of action by the staff.
You may contact Heather Clark at 202-551-3624 or Jean Yu at 202-551-3305 with any
questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing