SEC Comment Letter 0000000000-23-004984 to Amcor plc (AMCR, AMCCF) (CIK 0001748790) (AMCR)
Amcor plc (AMCR, AMCCF) (CIK 0001748790)
Date: May 11, 2023 · CIK: 0001748790 · Accession: 0000000000-23-004984
AI Filing Summary & Sentiment
File numbers found in text: 001-38932
Referenced dates: April 28, 2023
Letter
United States securities and exchange commission logo May 11, 2023 Michael Casamento Chief Financial Officer Amcor plc 83 Tower Road North Warmley, Bristol United Kingdom, BX308XP Re:Amcor plc Form 10-K for the Year Ended June 30, 2022 Form 10-Q for the Quarter Ended December 31, 2022 Form 8-K furnished February 7, 2023 Response Letter Dated April 28, 2023 File No. 001-38932 Dear Michael Casamento: We have reviewed your April 28, 2023 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 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. Unless we note otherwise, our references to prior comments are to comments in our March 31, 2023 letter. Response letter dated April 28, 2023 Form 10-K for the Year Ended June 30, 2022 Note 21. Segments, page 97 1.We note that in your response to our prior comment 4 you have provided gross profit margin trends for your five operating segments. Please also provide us with the applicable revenue amounts for each historic and forecasted period.
FirstName LastNameMichael Casamento Comapany NameAmcor plc May 11, 2023 Page 2 FirstName LastName Michael Casamento Amcor plc May 11, 2023 Page 2 Form 8-K furnished February 7, 2023 Exhibit 99.1 Earnings Release, page 14 2.We note from your response to our prior comment 6 that you use Adjusted Free Cash Flow as a financial performance measure. Please revise to reconcile only to the most directly comparable GAAP measure, which would be net income, rather than "net cash used from operating activities." Refer to item (10)(e)(i)(B) of Regulation S-K. Also, please explain to us, and revise your disclosure in future filings, to provide more detail including the quantification and nature of the cost components included in the adjustment for "Russia-Ukraine conflict impacts, material transaction and integration related costs." You may contact Claire Erlanger at (202) 551-3301 or Melissa Gilmore at (202) 551- 3777 if you have questions regarding comments on the financial statements and related matters. Sincerely, Division of Corporation Finance Office of Manufacturing
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United States securities and exchange commission logo
May 11, 2023
Michael Casamento
Chief Financial Officer
Amcor plc
83 Tower Road North
Warmley, Bristol
United Kingdom, BX308XP
Re:Amcor plc
Form 10-K for the Year Ended June 30, 2022
Form 10-Q for the Quarter Ended December 31, 2022
Form 8-K furnished February 7, 2023
Response Letter Dated April 28, 2023
File No. 001-38932
Dear Michael Casamento:
We have reviewed your April 28, 2023 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 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. Unless we note otherwise, our references to prior comments are to comments in our
March 31, 2023 letter.
Response letter dated April 28, 2023
Form 10-K for the Year Ended June 30, 2022
Note 21. Segments, page 97
1.We note that in your response to our prior comment 4 you have provided gross profit
margin trends for your five operating segments. Please also provide us with the applicable
revenue amounts for each historic and forecasted period.
FirstName LastNameMichael Casamento
Comapany NameAmcor plc
May 11, 2023 Page 2
FirstName LastName
Michael Casamento
Amcor plc
May 11, 2023
Page 2
Form 8-K furnished February 7, 2023
Exhibit 99.1 Earnings Release, page 14
2.We note from your response to our prior comment 6 that you use Adjusted Free Cash
Flow as a financial performance measure. Please revise to reconcile only to the most
directly comparable GAAP measure, which would be net income, rather than "net cash
used from operating activities." Refer to item (10)(e)(i)(B) of Regulation S-K. Also,
please explain to us, and revise your disclosure in future filings, to provide more detail
including the quantification and nature of the cost components included in the adjustment
for "Russia-Ukraine conflict impacts, material transaction and integration related costs."
You may contact Claire Erlanger at (202) 551-3301 or Melissa Gilmore at (202) 551-
3777 if you have questions regarding comments on the financial statements and related matters.
Sincerely,
Division of Corporation Finance
Office of Manufacturing