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United States securities and exchange commission logo
August 24, 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
Filed May 1, 2023
File No. 001-37668
Dear Beatriz Garc a-Cos:
We have reviewed your filing 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.
Form 20-F for the Fiscal Year Ended December 31, 2022
General
1. We note that you
provided more expansive disclosure in your 2021 Global ESG
report than you
provided in your SEC filings. Please advise us what consideration you
gave to providing the
same type of climate-related disclosure in your SEC filings as you
provided in your 2021
Global ESG report.
Key Information, page 5
2. To the extent material,
discuss the indirect consequences of climate-related regulation or
business trends, such
as the following:
decreased demand
for goods or products that produce significant greenhouse gas
emissions or are
related to carbon-based energy sources;
increased demand
for goods that result in lower emissions than competing products;
Beatriz Garc a-Cos
Ferroglobe PLC
August 24, 2023
Page 2
increased competition to develop innovative new products that
result in lower
emissions;
increased demand for generation and transmission of energy from
alternative energy
sources; and
any anticipated reputational risks resulting from operations or
products that produce
material greenhouse gas emissions.
3. If material, discuss the physical effects of climate change on your
operations and results.
This disclosure may include the following:
severity of weather, such as floods, hurricanes, sea levels,
arability of farmland,
extreme fires, and water availability and quality;
quantification of material weather-related damages to your
property or operations;
potential for indirect weather-related impacts that have affected
or may affect your
major customers or suppliers; and
any weather-related impacts on the cost or availability of
insurance.
Your response should include quantitative information for each of the
periods for which
financial statements are presented in your Form 20-F and explain
whether changes are
expected in future periods.
4. If material, provide disclosure about your purchase or sale of carbon
credits or offsets and
any material effects on your business, financial condition, and
results of operations. To the
extent applicable, ensure you provide quantitative information with
your response for each
of the periods for which financial statements are presented in your
Form 20-F and for any
future periods.
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 Michael Purcell at 202-551-5351 or Karina Dorin at
202-551-3763 with
any other questions.
FirstName LastNameBeatriz Garc a-Cos Sincerely,
Comapany NameFerroglobe PLC
Division of
Corporation Finance
August 24, 2023 Page 2 Office of Energy
& Transportation
FirstName LastName