SEC Comment Letter 0000000000-23-009320 to Ferroglobe PLC (GSM) (CIK 0001639877) (GSM)
Ferroglobe PLC (GSM) (CIK 0001639877)
Date: Aug. 24, 2023 · CIK: 0001639877 · Accession: 0000000000-23-009320
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File numbers found in text: 001-37668
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United States securities and exchange commission logo
August 24, 2023
Beatriz García-Cos
Chief Financial Officer and Principal Accounting Officer
Ferroglobe PLC
13 Chesterfield Street
London W1J 5JN, United Kingdom
Re:Ferroglobe PLC
Form 20-F for the Fiscal Year Ended December 31, 2022
Filed May 1, 2023
File No. 001-37668
Dear Beatriz García-Cos:
We have reviewed your filing 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. If you do not believe our
comments apply to your facts and circumstances, please tell us why in your response.
After reviewing your response to these comments, we may have additional comments.
Form 20-F for the Fiscal Year Ended December 31, 2022
General
1.We note that you provided more expansive disclosure in your 2021 Global ESG
report than you provided in your SEC filings. Please advise us what consideration you
gave to providing the same type of climate-related disclosure in your SEC filings as you
provided in your 2021 Global ESG report.
Key Information, page 5
2.To the extent material, discuss the indirect consequences of climate-related regulation or
business trends, such as the following:
•decreased demand for goods or products that produce significant greenhouse gas
emissions or are related to carbon-based energy sources;
•increased demand for goods that result in lower emissions than competing products;
FirstName LastNameBeatriz García-Cos
Comapany NameFerroglobe PLC
August 24, 2023 Page 2
FirstName LastName
Beatriz García-Cos
Ferroglobe PLC
August 24, 2023
Page 2
•increased competition to develop innovative new products that result in lower
emissions;
•increased demand for generation and transmission of energy from alternative energy
sources; and
•any anticipated reputational risks resulting from operations or products that produce
material greenhouse gas emissions.
3.If material, discuss the physical effects of climate change on your operations and results.
This disclosure may include the following:
•severity of weather, such as floods, hurricanes, sea levels, arability of farmland,
extreme fires, and water availability and quality;
•quantification of material weather-related damages to your property or operations;
•potential for indirect weather-related impacts that have affected or may affect your
major customers or suppliers; and
•any weather-related impacts on the cost or availability of insurance.
Your response should include quantitative information for each of the periods for which
financial statements are presented in your Form 20-F and explain whether changes are
expected in future periods.
4.If material, provide disclosure about your purchase or sale of carbon credits or offsets and
any material effects on your business, financial condition, and results of operations. To the
extent applicable, ensure you provide quantitative information with your response for each
of the periods for which financial statements are presented in your Form 20-F and for any
future periods.
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 Michael Purcell at 202-551-5351 or Karina Dorin at 202-551-3763 with
any other questions.
Sincerely,
Division of Corporation Finance
Office of Energy & Transportation