FORM 6-K
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549
Pursuant to Rule 13a
- 16 or 15d - 16 of
The Securities and Exchange Act of 1934
For the Month of May, 2005
HANSON PLC
1 Grosvenor Place, London, SW1X 7JH, England
[Indicate by check mark whether the registrant files or will file annual reports under cover Form 20-F or Form 40F.]
Form 20-F X Form 40-F
[Indicate by check mark whether the registrant by furnishing the information contained in this Form is also thereby furnishing the information to the Commission pursuant to Rule 12g3-2(b) under the Securities Exchange Act of 1934.]
Yes No X
May 9, 2005
Mr H R Schwall
Assistant Director
United States Securities and Exchange Commission
Divisions of Corporation Finance
450 Fifth Street, N.W.
Washington, D.C. 20549-0405
Finance Department
Direct line +44 (0)20 7259 4126
Direct fax +44 (0)20 7245 1296
Jonathan.nicholls@hansonplc.com
Ref: JCN\cmt\w:423\Han05
Dear Mr Schwall
Hanson plc
20-F for the fiscal year ended December 31, 2004
File no. 333-109672
In response to your letter of April 5, 2005 (and our subsequent correspondence
and telephone conversation), we would advise you that Hanson PLC provides
financial information analysed by its operational segments in its Annual Report
and Form 20F. These operational segments are based on its seven divisions:
Hanson North America Aggregates; Hanson North America Building Products; Hanson
UK Aggregates; UK Building Products; Hanson Australia; Hanson Asia Pacific; and
Hanson Continental Europe. This is consistent with the way that Hanson manages
its businesses and we have concluded that this meets United Kingdom and United
States disclosure requirements for segmental reporting.
We would propose that, with respect to proven and probable aggregates reserves;
a) we identify reserves by reference to the relevant operational segments
set out in our Annual Report and Form 20-F for fiscal 2004, i.e.
Hanson North America Aggregates; Hanson UK Aggregates; Hanson
Australia; Hanson Asia Pacific and Hanson Continental Europe;
b) we split such aggregates reserves in each of these operating segments
into crushed rock on the one hand and sand and gravel on the other.
We do not for the purposes of management information internally
distinguish between limestone and granite reserves, but generally
refer to crushed rock reserves;
c) we identify the percentage of such aggregates reserves in each
operating segment which are located on owned or leased property;
d) we provide a map for each operating segment and identify the individual
aggregates operations in that operating segment; and
e) we provide an estimate of the average expected life of such aggregates
reserves in each operating segment based on the production figures for
these operating segments for the year in which the Annual Report and
Form 20-F is to be prepared;
and with respect to proven and probable clay reserves;
a) we identify such clay reserves by reference to the two operating
segments that are applicable, i.e. Hanson North America Building
Products and Hanson UK Building Products;
b) we identify the percentage of such clay reserves in each of these two
operating segments which are located on owned or leased property;
c) we provide a map identifying the brick factories and clay reserves in
each of the two operating segments; and
d) we provide an estimate of the average expected life of the clay
reserves in each of these two operating segments based on the brick
production figures for the year in which the Annual Report and Form
20-F is to be prepared.
We believe that the above disclosures, with appropriate caveats, should provide
investors with adequate information about the group's mineral reserves,
recognising that the group has almost 420 crushed rock and sand and gravel
quarries throughout the world and more than 40 brick plants in the two operating
segments that are relevant, and that none of the individual operations
represented more than 3% of the group's overall annual aggregates production, or
more than 8% of the group's overall annual brick production respectively, based
on production figures for fiscal 2004. I trust that the above proposed
disclosure addresses your comments in your letter and look forward to receiving
your confirmation.
Yours sincerely
J C Nicholls
FINANCE DIRECTOR
May 27, 2005
Mr H. Roger Schwall
Assistant Director
United States Securities and Exchange Commission
Washington
D.C. 20549-0405
USA
Dear Mr Schwall,
In relation to my letter dated May 9, 2005 and our subsequent telephone conversation, Hanson
acknowledges that:
1) it is responsible for the adequacy and accuracy of the disclosures made in its filings with
the SEC;
2) SEC staff comments, or changes to disclosure in response to SEC staff comments, do not
foreclose the SEC from taking any action with respect to the filing; and
3) it may not assert SEC staff comments as a defence in any proceeding initiated by the SEC
under federal securities laws of the United States.
Yours sincerely,
Jonathan Nicholls
Finance Director
SIGNATURES
Pursuant to the requirements of the Securities Exchange Act of 1934, the registrant has duly caused this report to be signed on its behalf by the undersigned, thereunto duly authorised.
HANSON PLC
By:
/s/ Graham Dransfield
Date: May 27, 2005