April 15, 2004
First Time Application of International Financial Reporting Standards
We welcome the opportunity to comment on the SEC proposals to amend Form 20-F to provide a one-time accommodation relating to financial statements prepared under International Financial Reporting Standards IFRS for foreign private issuers registered or registering with the SEC. In this regard, we are generally supportive of the proposals, however we would comment specifically as follows.
Discussion of Proposed Accommodation to Permit Omission of IFRS Financial Statements for the Third Financial Year
We understand that eligibility for the proposed omission is in respect of only the first year of adoption and will require full compliance with all IFRS. We believe, in principle, that the proposals to permit omissions of IFRS financial statements for the third financial year are positive given the complexity associated with the initial introduction of IFRS reporting. However, as you will be aware, European domiciled companies are required to apply adopted IAS as determined by the European Commission. This process is outside the control of individual companies, and, as a result, they would be unable to make use of this exemption in circumstances where the EU did not fully adopt IAS.
We note that, where the exemption is taken, it is proposed that additional condensed US GAAP information as well as a full reconciliation to US GAAP be provided. We do not believe the provision of this information is unduly burdensome and would enable comparable information to be provided under US GAAP for a 3-year period.
Previous GAAP information may be useful for investors, although we believe this should be presented in as an appendix to the financial statements, and not as comparatives in the primary reports. This should neither be prohibited nor required.
Financial Statements and Information for Interim Periods for the Transition Year
We believe that it would be unduly burdensome to maintain books and records for previous GAAP and IFRS in the transition year. All of the comparative information is reconciled to US GAAP for both full and interim reporting periods, which will give underlying comparability for all periods.
Operating and Financial Review and Prospects
We believe that disclosure of the operating and financial review and prospects should be based on the primary reporting format at the time of the accounts. This is consistent with current practice.