View:
United States securities and exchange commission logo
August 25, 2022
Jeffrey L. Tate
Executive Vice President and Chief Financial Officer
Leggett & Platt, Incorporated
No. 1 Leggett Road
Carthage, Missouri 64836
Re: Leggett & Platt,
Incorporated
Form 10-K for
Fiscal Year Ended December 31, 2021
Filed February 22,
2022
File No. 001-07845
Dear Mr. Tate:
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 for Fiscal Year Ended December 31, 2021
General
1. We note that you
provided more expansive disclosure in your 2022 Sustainability Report
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 your 2022
Sustainability Report.
Risk Factors, page 17
2. Disclose the material
effects of transition risks related to climate change that may affect
your business,
financial condition, and results of operations, such as policy and regulatory
changes that could
impose operational and compliance burdens, market trends that may
alter business
opportunities, credit risks, or technological changes.
Jeffrey L. Tate
FirstName LastNameJeffrey
Leggett & Platt, IncorporatedL. Tate
Comapany
August 25, NameLeggett
2022 & Platt, Incorporated
August
Page 2 25, 2022 Page 2
FirstName LastName
3. Disclose any material litigation risks related to climate change and
explain the potential
impact to the company.
Management's Discussion and Analysis of Financial Condition and Results of
Operations, page
31
4. It appears you have identified climate-related projects in your
Sustainability Report, such
as projects to reduce carbon emissions and energy use. Tell us how you
considered
providing disclosure regarding past and future capital expenditures
for climate-related
projects. Include quantitative information for the periods covered by
your Form 10-K and
for future periods as part of your response.
5. To the extent material, please discuss the indirect consequences of
climate-related
regulation or business trends, such as the following:
decreased demand for goods or services that produce significant
greenhouse gas
emissions or are related to carbon-based energy sources;
increased demand for goods 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.
6. 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 material weather-related damages to your
property or operations;
and
potential for indirect weather-related impacts that have affected
or may affect your
major customers or suppliers.
As applicable, provide us with quantitative information in your
response for the periods
covered by your Form 10-K.
7. Disclosure on page 25 of your Form 10-K states that you have
experienced increased
property insurance premiums, in part, due to enhanced weather-related
risks. Please
provide us with quantitative information regarding the weather-related
impact on the cost
of insurance during the periods for which financial statements are
presented in your Form
10-K and tell us about any expected changes in future periods.
8. We note your disclosure on page 56 about compliance costs related to
climate change.
Please tell us about and quantify any compliance costs related to
climate change for each
of the last three fiscal years and explain whether increased amounts
are expected to be
incurred in future periods.
Jeffrey L. Tate
Leggett & Platt, Incorporated
August 25, 2022
Page 3
9. If material, please provide disclosure about any purchase or sale of
carbon credits or
offsets and any material effects on your business, financial
condition, and results of
operations. Include quantitative information for each of the periods
for which financial
statements are presented in your Form 10-K and for future periods as
part of your
response.
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 Erin Donahue at 202-551-6063 or Sergio Chinos at
202-551-7844 with
any questions.
FirstName LastNameJeffrey L. Tate Sincerely,
Comapany NameLeggett & Platt, Incorporated
Division of
Corporation Finance
August 25, 2022 Page 3 Office of
Manufacturing
FirstName LastName