SEC Comment Letter 0000000000-23-012049 to NOVO NORDISK A S (NVO, NONOF) (CIK 0000353278) (NVO)
NOVO NORDISK A S (NVO, NONOF) (CIK 0000353278)
Date: Nov. 3, 2023 · CIK: 0000353278 · Accession: 0000000000-23-012049
AI Filing Summary & Sentiment
File numbers found in text: 333-82318
Letter
United States securities and exchange commission logo November 3, 2023 Karsten Munk Knudsen Executive Vice President and Chief Financial Officer NOVO NORDISK A/S Novo Alle 1 DK-2880 Bagsværd Denmark Re:NOVO NORDISK A/S Form 20-F for the fiscal year ended December 31, 2022 Response dated October 20, 2023 File No. 333-82318 Dear Karsten Munk Knudsen: We have reviewed your October 20, 2023 response to our comment letter and have the following comment. 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 27, 2023 letter. Response dated October 20, 2023 General 1.We note your response to prior comment 1 states that based on your enterprise risk management process, you have concluded that none of the identified reputational risks related to your operations or products that results in greenhouse gas emissions are material. Please expand to discuss the specific reputational risks you identified and how you determined that they are not material. Please contact Anuja A. Majmudar, Attorney-Adviser, at (202) 551-3844 or Karina Dorin, Attorney-Adviser, at (202) 551-3763 with any questions.
FirstName LastNameKarsten Munk Knudsen Comapany NameNOVO NORDISK A/S November 3, 2023 Page 2 FirstName LastName Karsten Munk Knudsen NOVO NORDISK A/S November 3, 2023 Page 2 Sincerely, Division of Corporation Finance Office of Life Sciences
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United States securities and exchange commission logo
November 3, 2023
Karsten Munk Knudsen
Executive Vice President and Chief Financial Officer
NOVO NORDISK A/S
Novo Alle 1
DK-2880 Bagsværd
Denmark
Re:NOVO NORDISK A/S
Form 20-F for the fiscal year ended December 31, 2022
Response dated October 20, 2023
File No. 333-82318
Dear Karsten Munk Knudsen:
We have reviewed your October 20, 2023 response to our comment letter and have the
following comment.
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 27, 2023
letter.
Response dated October 20, 2023
General
1.We note your response to prior comment 1 states that based on your enterprise risk
management process, you have concluded that none of the identified reputational risks
related to your operations or products that results in greenhouse gas emissions are
material. Please expand to discuss the specific reputational risks you identified and how
you determined that they are not material.
Please contact Anuja A. Majmudar, Attorney-Adviser, at (202) 551-3844 or Karina
Dorin, Attorney-Adviser, at (202) 551-3763 with any questions.
FirstName LastNameKarsten Munk Knudsen
Comapany NameNOVO NORDISK A/S
November 3, 2023 Page 2
FirstName LastName
Karsten Munk Knudsen
NOVO NORDISK A/S
November 3, 2023
Page 2
Sincerely,
Division of Corporation Finance
Office of Life Sciences