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)