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                              December 20, 2023

       Stuart Ingall-Tombs
       Chief Financial Officer
       Rentokil Initial plc
       Compass House
       Manor Royal
       Crawley
       West Sussex RH10 9PY
       United Kingdom

                                                        Re: Rentokil Initial
plc
                                                            Form 20-F for the
Fiscal Year Ended December 31, 2022
                                                            File No. 001-41524

       Dear Stuart Ingall-Tombs:

                                                        We have reviewed your
filing 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.

       Form 20-F for the Fiscal Year Ended December 31, 2022

       Item 19. Exhibits
       Exhibits 12.1, 12.2 and 13.1, page 57

   1.                                                   Please provide
certifications under Exhibits 12.1, 12.2 and 13.1 that are dated. Refer to
                                                        instructions 12 and 13
in the Instructions to Exhibits of Form 20-F.
       Consolidated Financial Statements
       Consolidated Cash Flow Statement, page F-7

   2.                                                   Please relabel the cash
generated from operating activities title used throughout your
                                                        filings, so it is not
confusingly similar to net cash flows from operating activities. Cash
                                                        generated from
operations is the title used in the Illustrative Examples to IAS 7. Refer to
                                                        Item 10(e)(1)(ii)(E) of
Regulation S-K.
 Stuart Ingall-Tombs
FirstName  LastNameStuart  Ingall-Tombs
Rentokil Initial plc
Comapany20,
December    NameRentokil
               2023       Initial plc
December
Page 2     20, 2023 Page 2
FirstName LastName
Notes to the Financial Statements, page F-8

3.       Item 10(e)(1)(ii)(C) of Regulation S-K generally prohibits the
presentation of non-GAAP
         measures in the financial statement footnotes. Please remove the
non-IFRS measures from
         your footnotes or tell us how your financial statement footnote
disclosure for each non-
         IFRS measure meets the exception under Item 10(e)(5) of Regulation
S-K. Also, tell us
         how you comply with all presentation and disclosure requirements for
both Item
         10(e)(1)(i) of Regulation S-K and all IFRS (or other) guidance you
reference. Such
         measures may include adjusted profit before tax, adjusted income tax
expense, effective
         tax rate, adjusted interest, adjusted cash flow, free cash flow,
adjusted free cash flow and
         adjusted free cash flow conversion on pages F-18, F-36, F-64, F-65 and
F-66. Also, tell us
         your IFRS basis for including organic revenue measures in your
financial statement
         footnotes and explain why it is appropriate to (a) include estimated
revenue of acquired
         entities for pre-acquisition periods in your organic revenue growth
computations, since
         this estimated revenue does not appear to be yours, (b) treat Terminix
inconsistently with
         your organic revenue growth computation policy and differently from
other acquisitions
         and (c) refer to the estimated revenue as being pro forma, which
implies it was prepared
         pursuant to Article 11 of Regulation S-X.
        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 Keira Nakada at 202-551-3659 or Rufus Decker at
202-551-3769, if you
have any questions.



                                                               Sincerely,

                                                               Division of
Corporation Finance
                                                               Office of Trade
& Services