SEC Comment Letter for CINTAS (CTAS) — Oct 21, 2021
CINTAS CORP
Date: Oct. 21, 2021 · CIK: 0000723254 · Accession: 0000000000-21-012810
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United States securities and exchange commission logo
October 21, 2021
J. Michael Hansen
Chief Financial Officer
Cintas Corporation
6800 Cintas Boulevard
Cincinnati, OH 45262
Re:Cintas Corporation
Form 10-K for the Fiscal Year Ended May 31, 2021
Response Dated September 28, 2021
File No. 000-11399
Dear Mr. Hansen:
We have reviewed your September 28, 2021, response to our comment letter 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. Unless we note otherwise, our references to prior comments are to comments in our
September 16, 2021, letter.
Form 10-K for the Fiscal Year Ended May 31, 2021
General
1.Your response to prior comment 3, which states that you have not identified any material
indirect consequences of climate-related regulation or business trends, appears to be
conclusory without providing sufficient detail. Please provide us with additional support
for your conclusion, including with regard to the individual items noted in our prior
comment.
FirstName LastNameJ. Michael Hansen
Comapany NameCintas Corporation
October 21, 2021 Page 2
FirstName LastName
J. Michael Hansen
Cintas Corporation
October 21, 2021
Page 2
2.In response to prior comment 4, you indicate that you have not identified any significant
physical effects of climate change on your operations and results that are material. Your
response appears to be conclusory in nature, but does not address the specific elements of
our prior comment. Please tell us about the physical effects of climate change considered
in your response, address the factors from our prior comment, and provide an analysis of
materiality.
3.Your response to prior comment 5 states that you have not identified any effects of
transition risks related to climate change that are material to the company. Please describe
the transition risks you have identified and explain how you concluded their effects were
not material.
Please contact Jennifer Angelini at 202-551-3045 or Sergio Chinos at 202-551-7844 with
any questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing
cc: Brock Denton