SEC Comment Letter 0000000000-23-011444 to BUENAVENTURA MINING CO INC (BVN) (CIK 0001013131) (BVN)
BUENAVENTURA MINING CO INC (BVN) (CIK 0001013131)
Date: Oct. 19, 2023 · CIK: 0001013131 · Accession: 0000000000-23-011444
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File numbers found in text: 001-14370
Letter
United States securities and exchange commission logo October 19, 2023 Daniel Domínguez Chief Financial Officer Buenaventura Mining Company Inc. Las Begonias 415 Floor 19 San Isidro, Lima 27, Peru Re:Buenaventura Mining Company Inc. Form 20-F for the Fiscal Year Ended December 31, 2022 Response dated October 12, 2023 File No. 001-14370 Dear Daniel Domínguez: We have reviewed your October 12, 2023 response to our comment letter and have the following comments. 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. Form 20-F for Fiscal Year Ended December 31, 2022 Information on the Company, page 28 1.We note your response to prior comment 1 and reissue it in part. Please expand your disclosure to discuss whether, to date, you have experienced any of the indirect consequences of climate-related regulation or business trends noted in our prior comment. In addition, describe the internal analyses you utilized to determine that any decreased demand for goods or services that produce greenhouse gas emissions or are related to carbon-based energy sources would not have a material adverse effect on your operations or results of operations, and provide support for your determination of materiality. Explain how this internal analysis also supports your belief that an increase in demand for goods that result in lower emissions than competing products from precious metal mining companies could lead to an increase in demand for your products. Please also discuss the potential downsides you reference that may result from increased competition to develop
FirstName LastNameDaniel Domínguez Comapany NameBuenaventura Mining Company Inc. October 19, 2023 Page 2 FirstName LastName Daniel Domínguez Buenaventura Mining Company Inc. October 19, 2023 Page 2 innovative new products that results in lower emissions and your basis for stating that such downsides would likely have a marginal effect. 2.Your response to prior comment 1 states that you have not had any material reputational risk resulting from your operations or products that produce greenhouse gas emissions. Please expand your disclosure to discuss the potential adverse consequences to your reputation resulting from your operations that produce greenhouse gas emissions. 3.We note your response to prior comment 2 and reissue it in part. Please explain how you considered providing disclosure regarding the potential impact of UV radiation on your operations and results, including the cost of the remediation efforts discussed in your response. Please also revise your disclosure to discuss how your operations and results could be affected to the extent your customers or suppliers are impacted by severe weather.
In addition, please tell us the cost of all weather-related damages to your property or operations, and the cost of insurance, in each of the fiscal years ended December 31, 2022, 2021 and 2020. Please contact Michael Purcell at 202-551-5351 or Karina Dorin at 202-551-3763 with any questions. Sincerely, Division of Corporation Finance Office of Energy & Transportation
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United States securities and exchange commission logo
October 19, 2023
Daniel Domínguez
Chief Financial Officer
Buenaventura Mining Company Inc.
Las Begonias 415 Floor 19
San Isidro, Lima 27, Peru
Re:Buenaventura Mining Company Inc.
Form 20-F for the Fiscal Year Ended December 31, 2022
Response dated October 12, 2023
File No. 001-14370
Dear Daniel Domínguez:
We have reviewed your October 12, 2023 response to our comment letter and have the
following comments.
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.
Form 20-F for Fiscal Year Ended December 31, 2022
Information on the Company, page 28
1.We note your response to prior comment 1 and reissue it in part. Please expand your
disclosure to discuss whether, to date, you have experienced any of the indirect
consequences of climate-related regulation or business trends noted in our prior comment.
In addition, describe the internal analyses you utilized to determine that any decreased
demand for goods or services that produce greenhouse gas emissions or are related to
carbon-based energy sources would not have a material adverse effect on your operations
or results of operations, and provide support for your determination of materiality. Explain
how this internal analysis also supports your belief that an increase in demand for goods
that result in lower emissions than competing products from precious metal mining
companies could lead to an increase in demand for your products. Please also discuss the
potential downsides you reference that may result from increased competition to develop
FirstName LastNameDaniel Domínguez
Comapany NameBuenaventura Mining Company Inc.
October 19, 2023 Page 2
FirstName LastName
Daniel Domínguez
Buenaventura Mining Company Inc.
October 19, 2023
Page 2
innovative new products that results in lower emissions and your basis for stating that
such downsides would likely have a marginal effect.
2.Your response to prior comment 1 states that you have not had any material reputational
risk resulting from your operations or products that produce greenhouse gas emissions.
Please expand your disclosure to discuss the potential adverse consequences to your
reputation resulting from your operations that produce greenhouse gas emissions.
3.We note your response to prior comment 2 and reissue it in part. Please explain how you
considered providing disclosure regarding the potential impact of UV radiation on your
operations and results, including the cost of the remediation efforts discussed in your
response. Please also revise your disclosure to discuss how your operations and results
could be affected to the extent your customers or suppliers are impacted by severe
weather.
In addition, please tell us the cost of all weather-related damages to your property or
operations, and the cost of insurance, in each of the fiscal years ended December 31, 2022,
2021 and 2020.
Please contact Michael Purcell at 202-551-5351 or Karina Dorin at 202-551-3763 with
any questions.
Sincerely,
Division of Corporation Finance
Office of Energy & Transportation