CORRESP 1 filename1.txt 30th November 2006 Jim B Rosenberg Senior Assistant Chief Accountant United States Securities and Exchange Commission 450 Fifth Street NW Washington DC 20549 USA BY EDGAR Dear Mr Rosenberg Document: Form 20-F for the Fiscal Year Ended December 31, 2005 File Number: 000-201-4 Thank you for your letter dated November 16, 2006. We respond to your comment as set out below: Item 17. Financial Statements, page F-1 Notes To The Consolidated Financial Statements, page F-6 2. Accounting policies and basis of presentation, page F-6 Basis of preparation, page F-6 1. Refer to your response to our comment. Please provide us with a separate signed letter from your auditors stating their concurrence with your statement that your financial statements comply with IFRS as published by the IASB. Following a telephone conversation with the staff, we supplementally advise that we confirmed our original response in our letter dated September 29, 2006 with our auditors, PricewaterhouseCoopers LLP. We understand that we are responsible for the adequacy and accuracy of disclosure in our filings, staff comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to the filing; and we may not assert staff comments as a defence in any proceeding initiated by the Commission or any person under the federal securities laws of the United States. We look forward to hearing from you in due course. Yours sincerely A J Weir CFO cc: Richard Morrissey (Sullivan & Cromwell) PersonNameClifford Tompsett (PricewaterhouseCoopers LLP)