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October 16, 2018
Via E-mail
Walter M. Rosebrough, Jr.
President and Chief Executive Officer
STERIS plc
Rutherford House, Stephensons Way
Chaddesden, Derby DE21 6LY
United Kingdom
Re: STERIS plc
Form 10-K for the Fiscal Year Ended March 31, 2018
Filed May 30, 2018
File No. 1-37614
Dear Mr. Rosebrough:
We have limited our review of your filing to your contacts with a
country that has been
identified as a state sponsor of terrorism, and we have the following comment.
Our review with
respect to this issue does not preclude further review by the Assistant
Director group with respect
to other issues. At this juncture, we are asking you to provide us with
information so we may
better understand your disclosure.
Please respond to this letter within ten business days by providing the
requested
information, or by advising us when you will provide the requested response. If
you do not
believe our comment applies to your facts and circumstances, please tell us why
in your
response.
After reviewing the information you provide in response to this comment,
we may have
additional comments.
General
1. It appears from your website that your sales network in the Middle East
includes Syria.
Syria is designated by the U.S. Department of State as a state sponsor of
terrorism and is
subject to U.S. economic sanctions and export controls. You do not
include disclosure in
the Form 10-K about contacts with Syria. Please describe to us the nature
and extent of
any past, current and anticipated contacts with Syria, including with its
government,
whether through subsidiaries, distributors, dealers or other direct or
indirect
arrangements.
Walter M. Rosebrough, Jr.
STERIS plc
October 16, 2018
Page 2
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 Pradip Bhaumik, Special Counsel, at (202) 551-3333 or me
at (202) 551-
3470 if you have any questions about the comment or our review.
Sincerely,
/s/ Cecilia Blye
Cecilia Blye, Chief
Office of Global
Security Risk
cc: Amanda Ravitz
Assistant Director
Division of Corporation Finance