SECURITIES EXCHANGE ACT OF 1934
Release No. 50400 / September 16, 2004

ADMINISTRATIVE PROCEEDING
File No. 3-11668


In the Matter of

SENETEK PLC,

Respondent.


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ORDER INSTITUTING CEASE-AND-DESIST PROCEEDINGS, MAKING FINDINGS, AND IMPOSING A CEASE-AND-DESIST ORDER PURSUANT TO SECTION 21C OF THE SECURITIES EXCHANGE ACT OF 1934

I.

The Securities and Exchange Commission ("Commission") deems it appropriate that cease-and-desist proceedings be, and hereby are, instituted pursuant to Section 21C of the Securities Exchange Act of 1934 ("Exchange Act"), against Senetek PLC ("Senetek").

II.

In anticipation of the institution of these proceedings, Senetek has submitted an Offer of Settlement (the "Offer") which the Commission has determined to accept. Solely for the purpose of these proceedings and any other proceedings brought by or on behalf of the Commission, or to which the Commission is a party, and without admitting or denying the findings herein, except as to the Commission's jurisdiction over it and the subject matter of these proceedings, Senetek consents to the entry of this Order Instituting Cease-and-Desist Proceedings, Making Findings, and Imposing a Cease-and-Desist Order Pursuant to Section 21C of the Securities Exchange Act of 1934 ("Order"), as set forth below.

III.

On the basis of this Order and Senetek's Offer, the Commission finds that:

RESPONDENT

1. Senetek PLC, a public limited company organized under the laws of England, maintains its headquarters and principal place of operations in Napa, California. Senetek, which had annual sales of $8.2 million in 2003, is in the business of developing and marketing consumer dermatological products and biopharmaceuticals. Senetek American Depository Shares, which are registered pursuant to Section 12(g) of the Exchange Act, have been traded on the NASDAQ Smallcap Market since 1986 under the symbol SNTK.

FACTS

2. This matter involves Senetek's violation of Section 13(a) of the Exchange Act and Regulation FD on two separate occasions in 2002.

3. Prior to December 2001, there were no analysts who were actively providing research information about Senetek to the marketplace. To increase its visibility with investors, Senetek entered into an agreement with a research firm in December 2001 ("Firm A"). As part of this agreement, Senetek paid a monthly fee to the research firm, which, in exchange, agreed to publish research reports about the company.

4. In March 2002, Senetek entered into an agreement with a firm ("Firm B") pursuant to which Firm B agreed to render financial advisory services to Senetek in consideration for the payment of a monthly fee and other compensation. The financial advisory services enumerated in the agreement with Firm B did not specifically include preparation or publication of research reports. On May 28, 2002, an analyst engaged by Firm B sent an initial draft of a research report to Senetek's CEO for his review. This draft report contained, among other information, projected earnings for Senetek's fiscal year ending December 31, 2002.

5. On June 6, 2002, Senetek's CFO, at the direction of the CEO, sent Firm B an e-mail containing nonpublic information about the company's projected revenues and earnings for the 2002 fiscal year. The CFO's projections were materially lower than the projections contained in the draft report. Senetek did not simultaneously or promptly release these projections to the public.

6. On June 11, 2002, Firm B published its final report on Senetek. Based on the nonpublic data provided by Senetek's CFO, Firm B had lowered the earnings projections in its final report from the projections contained in the draft report provided to Senetek on May 28, 2002.

7. Similarly, Firm A sent a draft research report to Senetek for review on September 10, 2002. This draft report contained, among other information, projected revenues and earnings for Senetek's third and fourth quarters, ending September 30, 2002 and December 31, 2002, respectively, as well as for the 2002 fiscal year.

8. At the request of the CEO, Senetek's CFO reviewed Firm A's draft report. The CFO noted several computational errors in the draft report, which he corrected. More significantly, the CFO had developed new, nonpublic financial projections for the company's third and fourth quarters and for the year-end. Among other things, the CFO projected revenues and earnings for these periods that were materially lower than those contained in Firm A's draft report. The CFO prepared a spreadsheet containing these new projections and forwarded the spreadsheet to the CEO on September 25, 2002.

9. After reviewing the spreadsheet, the CEO changed some of the CFO's projections based on his personal knowledge about the company's operations. On September 26, 2003, the CEO's administrative assistant, at his direction, e-mailed the revised spreadsheet to Firm A and stated in the e-mail, "attached is an excel spreadsheet with the correct figures for your report." Senetek did not simultaneously or promptly release these projections to the public.

10. On September 30, 2002, Firm A published its final report on Senetek. Based on the nonpublic data provided by Senetek's CEO, Firm A had lowered the revenues and earnings projections in its final report from those contained in the draft report provided to Senetek on September 10, 2002.

VIOLATIONS

11. As a result of the conduct described above, Senetek violated Section 13(a) of the Exchange Act and Regulation FD by disclosing material, nonpublic information about Senetek's earnings in its private correspondence with analysts on two separate occasions without simultaneously or promptly publicly disclosing such information.

SENETEK'S REMEDIAL EFFORTS

12. In determining to accept the Offer, the Commission considered remedial acts promptly undertaken by Senetek and cooperation afforded the Commission staff.

IV.

In view of the foregoing, the Commission deems it appropriate to impose the relief specified in Senetek's Offer.

Accordingly, it is hereby ORDERED that Senetek cease and desist from committing or causing any violations and any future violations of Section 13(a) of the Exchange Act and Regulation FD thereunder.

By the Commission.

Jonathan G. Katz
Secretary