United States securities and exchange commission logo
October 6, 2023
Tracey T. Travis
Chief Financial Officer
The Est e Lauder Companies Inc.
767 Fifth Avenue
New York, New York 10153
Re: The Est e Lauder
Companies Inc.
Annual Report on
Form 10-K for the year ended June 30, 2023
Response Dated
September 27, 2023
File No. 001-14064
Dear Tracey T. Travis:
We have reviewed your September 27, 2023 response to our comment
letter and have the
following comments.
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. Unless
we note otherwise, any references to prior comments are to comments in
our September 14,
2023 letter.
Response dated September 27, 2023
Management's Discussion and Analysis of Financial Condition and Results
of Operations, page
28
1. We note your response
to prior comment 2. Please further address the following:
Tell us more
about the climate-related changes in demand and competition you have
experienced for
your products, including in relation to product packaging, sourcing,
and formulation.
Include an explanation of how you determined whether such
changes are due to
the factors identified in your response or due to climate-related
factors, and how
you assessed materiality, providing support for you determination.
Clarify whether
your SIS goals and targets (e.g., carbon neutrality across Scope 1 and
Scope 2 emissions
and sourcing 100% renewable energy for your direct operations)
Tracey T. Travis
The Est e Lauder Companies Inc.
October 6, 2023
Page 2
are related to changes in demand and competition for products
that result in lower
greenhouse gas emissions, are not derived from carbon-based
sources, and/or are
produced using alternative energy sources. In this regard, we
note disclosure of page
12 of your Form 10-K that, There continues to be increased
interest . . . in
responsibly-sourced ingredients and environmentally sustainable
products, and we
believe we are well-positioned to benefit from the resulting
changes in consumer
preferences due to our social impact and sustainability efforts,
in addition to related
risk factor disclosure on pages 18 and 19.
Your response indicates you have taken actions to mitigate the
risk of increasing
alternative energy costs, and that the cost of these actions to
date has not been
material. Provide support for your determination of materiality,
including quantitative
information for each of the periods covered by your Form 10-K and
expected to be
incurred in future periods.
2. We note your response to prior comment 3. Please further address the
following:
Provide us with quantitative information regarding
weather-related damages to your
property or operations for each of the periods covered by your
Form 10-K, rather than
the example of uninsured costs resulting from Hurricane Sandy in
2012.
Your response that the Company has not experienced a material
impact in instances
where your direct material suppliers experienced temporary
business impact due to
weather-related impacts appears conclusory in nature. Tell us
about the impact you
have experienced in these instances and how you evaluated
materiality, including by
providing the quantification requested by our prior comment.
Your response does not specifically address water-related
issues, although these
appear to be highlighted in your SIS Report, which states that
Access to high-quality
water is essential to our business. Tell us how you considered
disclosing the
importance of water to the Company and describing water-related
risks and
uncertainties, including your assessment of materiality on your
business and
operations.
Please contact Benjamin Richie at 202-551-7857 or Jennifer Angelini at
202-551-3047
with any questions.
Sincerely,
FirstName LastNameTracey T. Travis
Division of
Corporation Finance
Comapany NameThe Est e Lauder Companies Inc.
Office of
Industrial Applications and
October 6, 2023 Page 2 Services
FirstName LastName