SEC Comment Letter for COCA-COLA EUROPACIFIC PARTNERS (CCEP) — Jun 23, 2017
COCA-COLA EUROPACIFIC PARTNERS plc
Date: June 23, 2017 · CIK: 0001650107 · Accession: 0000000000-17-022111
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Mail Stop 3561 June 23 , 2017 Mr. Nik Jhangiani Chief Financial Officer Coca -Cola European Partners PLC Bakers Road, Uxbridge UB8 1EZ United Kingdom Re: Coca -Cola European Partners PLC Form 20-F for Year Ended December 31, 2016 Response dated May 31, 2017 File No. 1 -37791 Dear Mr. Jhangiani : We have reviewed your May 31, 2017 response to our comment letter 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 busine ss days by providing the requested information or advis e us as soon as possible when you will respond. If you do not believe our comments a pply to your facts and circumstances, please tell us why in your response. After reviewing your response to these comments, we may have additional comments. Unless we note otherwise, our references to prior comments are to c omments in our May 17, 2017 letter . Financial Statements Note 3. Segment Information, page 106 1. We have reviewed your response to comment 3 and require further information in order to evaluate your response. Please address the following matters with respect to your Board –as your CODM –and your CEO: a. Describe what consideration was given to your CEO being your CODM. b. Elaborate more on the activities and decisions of the Board versus activities and decisions of the CEO. c. You state that the Board makes decisions with res pect to capital investments, restructuring activities such as production and distribution facility rationalization or Mr. Nik Jhangiani Coca -Cola European Partners PLC June 23, 2017 Page 2 route -to-market changes, pan -European or local product and package innovations, and licensing agreements. Explain how frequently these ty pes of decisions are made by the Board and whether any thresholds exist for required Board approval. d. Indicate how frequently the CEO meets with the general managers of your geographic business units. e. Compare and contrast how the roles and responsibil ities of the CEO –as the CODM – and the Board of CCE, your predecessor, differ from those of the CEO and the Board of CCEP. 2. You state that the CODM reviews and utilizes consolidated results to evaluate performance and allocate resources. Please explain how the CODM makes decisions about marketplace investment, production or distribution facility rationalization, route -to- marke t changes, and local product and package innovations, and license agreements using consolidated information. Please also include a discussion of any limitations to the CEO’s decision making authority as it relates to resource allocation, evaluation of performance and the other key decisions described above. 3. Please describe the types and frequency of financial information that the CEO receives about the five geographical business units. Also, indicate the nature and frequency of any discussions of this information which the CEO provides to the Board. 4. Please describe the basis for determining the compensation for the general managers of your five geographical business units. You may contact Linda Cvrkel at (202) 551-3813 or me at (202) 551-3769 with an y questions. Sincerely, /s/ Rufus Decker Rufus Decker Accounting Branch Chief Office of Beverages, Apparel and Mining