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United States securities and exchange commission logo
October 4, 2023
Beatriz Garc a-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
Response dated
September 21, 2023
File No. 001-37668
Dear Beatriz Garc a-Cos:
We have reviewed your September 21, 2023 response to our comment
letter and have the
following comments.
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. Unless
we note otherwise, any references to prior comments are to comments in
our August 24,
2023 letter.
Form 20-F for the Fiscal Year Ended December 31, 2022
Key Information, page 5
1. We note your response
to prior comment 2 that you did not experience any material
indirect consequences
of climate-related regulation or business trends. However, you also
state you are actively
developing carbon reduction targets and initiatives and are aiming to
meet the expectations
of your stakeholders that are beginning to demand products with a
lower carbon footprint.
Please include a discussion explaining in greater detail your
analysis and how you
concluded on materiality for each of the items noted below:
decreased demand
for goods or products that produce significant greenhouse gas
emissions or are
related to carbon-based energy sources, including the basis for your
statement that you
do not anticipate a significant change in the industry's technology
for production of
the products you produce;
Beatriz Garc a-Cos
FirstName
Ferroglobe LastNameBeatriz Garc a-Cos
PLC
Comapany
October NameFerroglobe PLC
4, 2023
October
Page 2 4, 2023 Page 2
FirstName LastName
increased demand for goods that result in lower emissions than
competing products;
and
increased competition to develop innovative new products that
result in lower
emissions.
Your response also indicates that your risk factor disclosure on page
10 addresses
reputation risks relating to your operations that produce material
greenhouse gas
emissions. However, such discussion appears to focus on the impact to
your reputation
that may result from a regulatory violation. Please tell us what
consideration you have
given to including disclosure regarding any potential reputation risks
from your operations
that produce greenhouse gas emissions, including from stakeholders,
customers and
lenders.
2. We note your response to prior comment 3. Please further address the
following:
Your response acknowledges that there is always the potential for
natural disasters
and extreme weather conditions to occur as a result of global
climate change. Your
response also indicates that you have experienced non-material
direct impacts as a
result of weather-related incidents in recent years. Please explain
how you assessed
the materiality of weather-related incidents and quantify all
weather-related damages
to your property and operations.
Your 2021 Global ESG report reflects that your water consumption
totaled 27.7M
cubic meters and is made up of 43% surface water, 37% from third
parties and 20%
ground water. Please tell us how you considered including
disclosure regarding the
impact of water availability and quality to your operations and
results.
Please revise your disclosure to address how you could be impacted
if severe weather
impacts your customers or suppliers. In this regard, we note your
response reflects
Colombia has experienced heavy rains and South Africa and the
United States have
suffered from flooding, and your Form 20-F reflects that 59% of
your third-party coal
purchases came from a single mine in Colombia and nearly all the
manganese ore
you purchase comes from suppliers in South Africa and Gabon.
Your response states that your property insurance underwriting
rate has consistently
measured between 1.4 and 1.5. Please provide us with information
quantifying the
cost of property insurance for each of the periods for which
financial statements are
presented in your Form 20-F and whether you expect any future
period changes to the
cost of insurance.
Please contact Michael Purcell at 202-551-5351 or Karina Dorin at
202-551-3763 with
any questions.
Sincerely,
Division of
Corporation Finance
Beatriz Garc a-Cos
Ferroglobe PLC
FirstName
October LastNameBeatriz Garc a-Cos
4, 2023
Page 3
Comapany NameFerroglobe PLC
October 4, 2023 Page 3 Office of Energy & Transportation
FirstName LastName