SecProbe.io

United States securities and exchange commission logo
April 18, 2024
Tobias Hestler
Chief Financial Officer
Haleon plc
Building 5, First Floor
The Heights
Weybridge
KT13 0NY
United Kingdom
Re:Haleon plc
Form 20-F filed March 15, 2024
File No. 001-41411
Dear Tobias Hestler:
            We have limited our review of your filing to the financial statements and related
disclosures 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 20-F filed March 15, 2024
Use of Non-IFRS Measures, page 43
1.You indicate that beginning in 2024, your organic revenue growth calculation will cap
pricing in excess of 26 percent per annum for countries
experiencing hyperinflation. Please explain the basis for this change and address the
impact that this revision may have on your calculations.
2.Your tabular presentations on page 44 give the appearance of a full non-
IFRS income statement. This may place undue prominence on the non-IFRS information
and give the impression that the non-IFRS income statement represents a comprehensive
basis of accounting. Confirm to us that you will revise your tabular presentations
accordingly. Refer to Question 102.10(a) and (c) of the Compliance and Disclosure
Interpretations on Non-GAAP Financial Measures. Address this comment as it relates to

 FirstName LastNameTobias  Hestler
 Comapany NameHaleon plc
 April 18, 2024 Page 2
 FirstName LastName
Tobias  Hestler
Haleon plc
April 18, 2024
Page 2
your Form 6-K filed February 29, 2024, which furnishes your press release entitled 2023
Full Year Results.

Financial Statements
Note 1. General Information, page 121
3.Please disclose the date when the financial statements were authorized for issue and who
gave that authorization. Refer to paragraph 17 of IAS 10.
Note 19.Borrowings, page 143
4.With reference to the List of Subsidiary Issuers of Guaranteed Securities as set forth in
Exhibit 22, please tell us how you considered the disclosure requirements in Rule 13-01 of
Regulation S-X.
Change In Certifying Accountant, page 192
5.We have the following comments related to your change in certifying accountant
disclosures:
•Disclose the date that KPMG US declined to stand for re-election as required by Item
16F(a)(1)(i) of the Form 20-F;
•You state that there have been no disagreements or reportable events with KPMG US
in respect of the financial year ended December 31, 2022. Please tell us if there were
any disagreements or reportable events with KPMG US in the subsequent interim
period ending April 20, 2023. Refer to Item 16F(a)(1)(iv) and (v) of the Form 20-F;
and
•File as an exhibit the letter from KPMG US as required pursuant to Item
16(F)(a)(3) of the Form 20-F.
            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
absence of action by the staff.
            Please contact Jeanne Baker at 202-551-3691 or Terence O'Brien at 202-551-3355 with
any questions.
Sincerely,
Division of Corporation Finance
Office of Industrial Applications and
Services