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August 22, 2023
Kenneth D. Tuchman
Chairman and Chief Executive Officer
TTEC Holdings, Inc.
6312 South Fiddlers Green Circle
Suite 100N
Greenwood Village, CO 80111
Re:TTEC Holdings, Inc.
Definitive Proxy Statement on Schedule 14A
Filed April 11, 2023
File No. 001-11919
Dear Kenneth D. Tuchman:
            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 revise your future proxy disclosures in accordance with the topics discussed below.
Definitive Proxy Statement on Schedule 14A filed April 11, 2023
Pay Versus Performance, page 53
1.In footnote 1, please ensure that you identify each named executive officer included in the
calculation of average non-PEO compensation for every year presented, including the
most recent fiscal year. See Regulation S-K Item 402(v)(3).
2.We note that you include Revenue, Adjusted Operating Income, and Adjusted EBITDA as
your Company-Selected Measures. Regulation S-K Item 402(v)(2)(vi) permits you to
designate only one Company-Selected Measure, which, in your assessment, "represents
the most important financial performance measure (that is not otherwise required to be
disclosed in the table) used by [you] to link compensation actually paid to [your] named
executive officers, for the most recently completed fiscal year, to company performance."
Please ensure that you include only one Company-Selected Measure in the pay versus
performance table.

You may elect to provide in the table one or more performance measures in addition to the
Company-Selected Measure, provided that the disclosures about those measures "may not
be misleading or obscure the required information, and the additional performance
measures may not be presented with greater prominence than the required disclosure." See

 FirstName LastNameKenneth D. Tuchman
 Comapany NameTTEC Holdings, Inc.
 August 22, 2023 Page 2
 FirstName LastName
Kenneth D. Tuchman
TTEC Holdings, Inc.
August 22, 2023
Page 2
Pay Versus Performance, Release No. 34–95607 (Apr. 29, 2015) [87 FR 55134 (Sept. 8,
2022)] at 55159. Note that each additional measure must also be accompanied by a clear
description of the relationship between executive compensation actually paid to your
PEO, and, on average, to the other named executive officers, and that measure, across the
fiscal years presented. See Regulation S-K Item 402(v)(5)(iv).
3.We note that you include in the pay versus performance table the non-GAAP measures
Adjusted Operating Income and Adjusted EBITDA, and we note your tabular disclosure
of "GAAP vs. Adjusted Performance." Please ensure that you provide disclosure showing
how these numbers are calculated from your audited financial statements, as required
by Regulation S-K Item 402(v)(2)(vi). If the disclosure appears in a different part of the
definitive proxy statement, you may satisfy the disclosure requirement by a cross-
reference thereto; however, incorporation by reference to a separate filing will not satisfy
this disclosure requirement.
4.While we note your disclosure "Company TSR and Peer Group TSR" on page 55, it
appears that you have not provided all of the relationship disclosures required by
Regulation S-K Item 402(v)(5). Please ensure that you provide this required disclosure in
its entirety. Although you may provide this information graphically, narratively, or a
combination of the two, this disclosure must be separate from the pay versus performance
table required by Regulation S-K Item 402(v)(1) and must provide a clear description of
each separate relationship indicated in Regulation S-K Item 402(v)(5)(i)-(iv). Please note,
it is not sufficient to state that no relationship exists, even if a particular measure is not
used in setting compensation.
5.In calculating the compensation actually paid for the non-PEO named executive officers,
you indicate that you exclude the value of certain outstanding and unvested performance-
based equity awards that were granted in the covered fiscal year. Regulation S-K Item
402(v)(2)(iii)(C)(1)(i) requires that you include the "fair value as of the end of the covered
fiscal year of all awards granted during the covered fiscal year that are outstanding and
unvested as of the end of the covered fiscal year." In your calculations of
compensation actually paid, please ensure that you include the fair values required by
Regulation S-K Item 402(v)(2)(iii)(C)(1)(i).
            Please contact Eric Envall at 202-551-3234 or Charlie Guidry at 202-551-3621 with any
questions.
Sincerely,
Division of Corporation Finance
Disclosure Review Program