SEC Comment Letter for COCA COLA CO (KO) (CIK 0000021344) (KO) — Sep 2, 2022
COCA COLA CO (KO) (CIK 0000021344)
Date: Sept. 2, 2022 · CIK: 0000021344 · Accession: 0000000000-22-009611
AI Filing Summary & Sentiment
File numbers found in text: 001-02217
Letter
United States securities and exchange commission logo September 2, 2022 James Quincey Chairman and Chief Executive Officer The Coca-Cola Company One Coca-Cola Plaza Atlanta, Georgia 30313 Re:The Coca-Cola Company Definitive Proxy Statement on Schedule 14A Filed March 11, 2022 File No. 001-02217 Dear Mr. Quincey: We have limited our review of your most recent definitive proxy statement to those issues we have addressed in our comments. Please respond to these comments by confirming that you will enhance your future proxy disclosures in accordance with the topics discussed below as well as any material developments to your risk oversight structure. For guidance, refer to Item 407(h) of Regulation S-K. Definitive Proxy Statement on Schedule 14A filed March 11, 2022 General 1.Please expand your discussion to address how the experience of the Lead Independent Director is brought to bear in connection with your board’s role in risk oversight. 2.Please expand upon the role that your Lead Independent Director plays in the leadership of the board. For example, please enhance your disclosure to address whether or not your Lead Independent Director may: •represent the board in communications with shareholders and other stakeholders; •require board consideration of, and/or override your CEO on, any risk matters; or •provide input on the design of the board itself. 3.Please expand upon how your board administers its risk oversight function. For example, please disclose: •the timeframe over which you evaluate risks (e.g., short-term, intermediate-term, or long-term) and how you apply different oversight standards based upon the immediacy of the risk assessed; •whether you consult with outside advisors and experts to anticipate future threats and
FirstName LastNameJames Quincey Comapany NameThe Coca-Cola Company September 2, 2022 Page 2 FirstName LastName James Quincey The Coca-Cola Company September 2, 2022 Page 2 trends, and how often you re-assess your risk environment; •how the board interacts with management to identify significant emerging risks; •to whom the Chief Ethics and Compliance Officer reports; and •how your risk oversight process aligns with your disclosure controls and procedures. 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 Jennifer Gowetski at 202-551-3401 or Amanda Ravitz at 202-551-3412 with any questions. Sincerely, Division of Corporation Finance Disclosure Review Program
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United States securities and exchange commission logo
September 2, 2022
James Quincey
Chairman and Chief Executive Officer
The Coca-Cola Company
One Coca-Cola Plaza
Atlanta, Georgia 30313
Re:The Coca-Cola Company
Definitive Proxy Statement on Schedule 14A
Filed March 11, 2022
File No. 001-02217
Dear Mr. Quincey:
We have limited our review of your most recent definitive proxy statement to those issues
we have addressed in our comments.
Please respond to these comments by confirming that you will enhance your future proxy
disclosures in accordance with the topics discussed below as well as any material developments
to your risk oversight structure. For guidance, refer to Item 407(h) of Regulation S-K.
Definitive Proxy Statement on Schedule 14A filed March 11, 2022
General
1.Please expand your discussion to address how the experience of the Lead Independent
Director is brought to bear in connection with your board’s role in risk oversight.
2.Please expand upon the role that your Lead Independent Director plays in the leadership
of the board. For example, please enhance your disclosure to address whether or not your
Lead Independent Director may:
•represent the board in communications with shareholders and other stakeholders;
•require board consideration of, and/or override your CEO on, any risk matters; or
•provide input on the design of the board itself.
3.Please expand upon how your board administers its risk oversight function. For example,
please disclose:
•the timeframe over which you evaluate risks (e.g., short-term, intermediate-term, or
long-term) and how you apply different oversight standards based upon the
immediacy of the risk assessed;
•whether you consult with outside advisors and experts to anticipate future threats and
FirstName LastNameJames Quincey
Comapany NameThe Coca-Cola Company
September 2, 2022 Page 2
FirstName LastName
James Quincey
The Coca-Cola Company
September 2, 2022
Page 2
trends, and how often you re-assess your risk environment;
•how the board interacts with management to identify significant emerging risks;
•to whom the Chief Ethics and Compliance Officer reports; and
•how your risk oversight process aligns with your disclosure controls and procedures.
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 Jennifer Gowetski at 202-551-3401 or Amanda Ravitz at 202-551-3412
with any questions.
Sincerely,
Division of Corporation Finance
Disclosure Review Program