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                             June 10, 2024

       Ivan Hsia
       Chief Financial Officer
       Asia Pacific Wire & Cable Corporation Limited
       15/Fl. B, No. 77, Sec. 2
       Dunhua South Road
       Taipei, 106, Taiwan
       Republic of China

                                                        Re: Asia Pacific Wire & 
Cable Corporation Limited
                                                            Form 20-F for the 
Year Ended December 31, 2023
                                                            Filed April 29, 
2024
                                                            File No. 001-14542

       Dear Ivan Hsia:

              We have limited our review of your filing to the financial 
statements and related
       disclosures and have the following comment(s).

              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 Year Ended December 31, 2023

       Financial Statements
       Notes to the Consolidated Financial Statements
       27. Financial Risk Management Objectives
       27(d) Capital management, page F-84

   1.                                                   We refer to    net debt 
   and    gearing ratio.    Please tell us whether these measures are
                                                        currently required to 
be disclosed by your home country or other applicable securities
                                                        regulators. If these 
measures are not currently required to be disclosed by IFRS,
                                                        Commission Rules, or 
regulatory requirements, it appears that they are non-
                                                        IFRS measures as 
defined by Item 10(e)(2) in Regulation S-K. Therefore, please expand
                                                        your disclosure in your 
future filings to explain how it was calculated, and provide
                                                        reconciliation to the 
most directly comparable IFRS measure. Refer to General
                                                        Instruction C(e) of 
Form 20-F. To the extent this is not required by IFRS, please revise to
 Ivan Hsia
Asia Pacific Wire & Cable Corporation Limited
June 10, 2024
Page 2
         remove this apparent non-IFRS measure from your financial statement 
footnotes. Refer to
         Item 10(e)(1)(ii)(C) of Regulation S-K.

       In closing, 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 Heather Clark at 202-551-3624 or Melissa Gilmore at 
202-551-3777 with
any questions.



FirstName LastNameIvan Hsia                          Sincerely,
Comapany NameAsia Pacific Wire & Cable Corporation Limited
                                                     Division of Corporation 
Finance
June 10, 2024 Page 2                                 Office of Manufacturing
FirstName LastName