SEC Comment Letter 0000000000-23-009675 to LENNOX INTERNATIONAL INC (LII)
LENNOX INTERNATIONAL INC
Date: Aug. 31, 2023 · CIK: 0001069202 · Accession: 0000000000-23-009675
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File numbers found in text: 001-15149
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United States securities and exchange commission logo
August 31, 2023
Joseph Reitmeier
Chief Financial Officer
Lennox International Inc.
2140 Lake Park Blvd.
Richardson, Texas 75080
Re:Lennox International Inc.
Form 10-K For Fiscal Year Ended December 31, 2022
Filed February 21, 2023
File No. 001-15149
Dear Joseph Reitmeier:
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 filed February 21, 2023
General
1.We note that you provided more expansive disclosure in your Environmental Social
Governance Report 2021 ("ESG 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 ESG Report.
FirstName LastNameJoseph Reitmeier
Comapany NameLennox International Inc.
August 31, 2023 Page 2
FirstName LastName
Joseph Reitmeier
Lennox International Inc.
August 31, 2023
Page 2
Management's Discussion and Analysis of Financial Condition and Results of Operations, page
17
2.To the extent material, 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;
•any anticipated reputational risks resulting from operations or products that produce
material greenhouse gas emissions; and
•potential climate-related opportunities, such as the development of electric heat
pumps and refrigerants with lower global warming potential.
3.We note your disclosure that the effects of climate change include extreme weather
events, long-term changes in temperature levels, and water availability. 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 weather-related damages to your property or operations;
•potential for indirect weather-related impacts that have affected or may affect your
major customers or suppliers; and
•the extent to which extreme weather events have reduced the availability of insurance
or increased the cost of insurance.
Include quantitative information for each of the periods covered by your Form 10-K and
explain whether increased amounts are expected in future periods.
4.Your ESG Report references the purchase of renewable energy credits ("RECs"). If
material, please provide disclosure about your purchase and sale of carbon credits, carbon
offsets, or RECs, and any material effects on your business, financial condition, and
results of operations. Provide us with quantitative information for each of the periods
covered by your most recent Form 10-K and the amounts budgeted for or expected to be
incurred in future periods.
FirstName LastNameJoseph Reitmeier
Comapany NameLennox International Inc.
August 31, 2023 Page 3
FirstName LastName
Joseph Reitmeier
Lennox International Inc.
August 31, 2023
Page 3
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 Charli Gibbs-Tabler at 202-551-6388 or Jennifer Angelini at 202-551-
3047 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Technology