SEC Comment Letter for LEGGETT & PLATT INC (LEG) (CIK 0000058492) (LEG) — Aug 25, 2022
LEGGETT & PLATT INC (LEG) (CIK 0000058492)
Date: Aug. 25, 2022 · CIK: 0000058492 · Accession: 0000000000-22-009225
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File numbers found in text: 001-07845
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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.
FirstName LastNameJeffrey L. Tate
Comapany NameLeggett & Platt, Incorporated
August 25, 2022 Page 2
FirstName LastName
Jeffrey L. Tate
Leggett & Platt, Incorporated
August 25, 2022
Page 2
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.
FirstName LastNameJeffrey L. Tate
Comapany NameLeggett & Platt, Incorporated
August 25, 2022 Page 3
FirstName LastName
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.
Sincerely,
Division of Corporation Finance
Office of Manufacturing