SEC Comment Letter 0000000000-24-002497 to Ferguson plc (CIK 0001832433)
Ferguson plc (CIK 0001832433)
Date: March 6, 2024 · CIK: 0001832433 · Accession: 0000000000-24-002497
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File numbers found in text: 001-40066
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United States securities and exchange commission logo
March 6, 2024
William Brundage
Chief Financial Officer
Ferguson plc
1020 Eskdale Road, Winnersh Triangle, Wokingham
Berkshire, RG41 5TS
United Kingdom
Re:Ferguson plc
Form 10-K for the Fiscal Year Ended July 31, 2023
File No. 001-40066
Dear William Brundage:
We have reviewed your filing and have the following comment(s).
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.
Form 10-K for the Fiscal Year Ended July 31, 2023
General
1.On page XII of your Annual Report to Shareholders you present adjusted operating profit
and adjusted EPS-diluted. Please revise to present the most directly comparable GAAP
measures to these non-GAAP measures. Refer to Rule 100(a)(1) of Regulation G.
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.
FirstName LastNameWilliam Brundage
Comapany NameFerguson plc
March 6, 2024 Page 2
FirstName LastName
William Brundage
Ferguson plc
March 6, 2024
Page 2
Please contact James Giugliano at 202-551-3319 or Joel Parker at 202-551-3651 if you
have questions regarding comments on the financial statements and related matters.
Sincerely,
Division of Corporation Finance
Office of Trade & Services