United States securities and exchange commission logo
August 21, 2023
Safra Catz
Chief Executive Officer
Oracle Corporation
2300 Oracle Way
Austin, Texas 78741
Re: Oracle Corporation
Form 10-K for
Fiscal Year Ended May 31, 2023
Filed June 20, 2023
File No. 001-35992
Dear Safra Catz:
We have reviewed your filing and have the following comments. In
some of our
comments, we may ask you to provide us with information so we may better
understand your
disclosure.
Please respond to these comments 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 our
comments apply to your facts and circumstances, please tell us why in
your response.
After reviewing your
response to these comments, we may have additional comments.
Form 10-K filed June 20, 2023
General
1. We note that you
provided more expansive disclosure in your Social Impact Report and
Social Impact Datasheet
than you provided in your SEC filings. Please advise us what
consideration you gave
to providing the same type of climate-related disclosure in your
SEC filings as you
provided in these documents.
Safra Catz
FirstName LastNameSafra Catz
Oracle Corporation
Comapany
August 21, NameOracle
2023 Corporation
August
Page 2 21, 2023 Page 2
FirstName LastName
Management's Discussion and Analysis of Analysis of Financial Condition and
Results of
Operations,, page 35
2. To the extent material, discuss the indirect consequences of
climate-related regulation or
business trends, such as the following:
decreased demand for products or services that produce
significant greenhouse gas
emissions or are related to carbon-based energy sources;
increased demand for products or services that result in lower
emissions than
competing products;
increased competition to develop innovative new products that
result in lower
emissions;
increased demand for generation and transmission of energy from
alternative energy
sources; and
any anticipated reputational risks resulting from operations or
products that produce
material greenhouse gas emissions.
3. We note disclosure on page 31 of the Form 10-K that your critical
business operations are
concentrated in a few geographic areas and that major natural
disasters or the effects of
climate change, such as increased storm severity or drought, are risks
to your business.
Please discuss the physical effects of climate change on your
operations and results. This
disclosure may include the following:
severity of weather, such as floods, hurricanes, sea levels,
extreme fires, and water
availability and quality;
quantification of weather-related damages to your property or
operations;
potential for indirect weather-related impacts that have
affected or may affect your
major customers or suppliers; and
the extent to which extreme weather events have reduced the
availability of insurance
or increased the cost of insurance.
Include quantitative information for each of the periods covered by
your Form 10-K and
explain whether increased amounts are expected in future periods.
4. Please provide disclosure about your purchase and sale of carbon
credits, carbon offsets,
or energy attribute certificates, and any material effects on your
business, financial
condition, and results of operations. Provide us with quantitative
information for each of
the periods covered by your most recent Form 10-K and the amounts
budgeted for or
expected to be incurred in future periods.
Safra Catz
FirstName LastNameSafra Catz
Oracle Corporation
Comapany
August 21, NameOracle
2023 Corporation
August
Page 3 21, 2023 Page 3
FirstName LastName
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 Charli Gibbs-Tabler at 202-551-6388 or Jennifer Angelini
at 202-551-
3047 with any other questions.
Sincerely,
Division of
Corporation Finance
Office of Technology