SEC Comment Letter 0000000000-24-009161 to Xylem Inc. (XYL) (CIK 0001524472) (XYL)
Xylem Inc. (XYL) (CIK 0001524472)
Date: Aug. 9, 2024 · CIK: 0001524472 · Accession: 0000000000-24-009161
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 001-35229
Letter
August 9, 2024 Matthew F. Pine President and Chief Executive Officer Xylem Inc. 301 Water Street SE Washington, DC 20003 Re:Xylem Inc. Definitive Proxy Statement on Schedule 14A Filed April 2, 2024 File No. 001-35229 Dear Matthew F. Pine: We have limited our review of your most recent definitive proxy statement to those issues we have addressed in our comment(s). Please respond to this letter by providing the requested information and/or confirming that you will revise your future proxy disclosures in accordance with the topics discussed below. 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. Definitive Proxy Statement on Schedule 14A Pay Versus Performance, page 65 1.We note that you have included Revenue as your Company-Selected Measure pursuant to Item 402(v)(2)(vi) of Regulation S-K. Please include your Company-Selected Measure in the Tabular List provided pursuant to Item 402(v)(6) of Regulation S-K. In that regard, we note that you included “Organic Revenue” in your Tabular List, but not Revenue.
August 9, 2024 Page 2 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 Laura Nicholson at 202-551-3584 or Amanda Ravitz at 202-551-3412 with any questions. Sincerely, Division of Corporation Finance Disclosure Review Program
Show Raw Text
August 9, 2024
Matthew F. Pine
President and Chief Executive Officer
Xylem Inc.
301 Water Street SE
Washington, DC 20003
Re:Xylem Inc.
Definitive Proxy Statement on Schedule 14A
Filed April 2, 2024
File No. 001-35229
Dear Matthew F. Pine:
We have limited our review of your most recent definitive proxy statement to those issues
we have addressed in our comment(s).
Please respond to this letter by providing the requested information and/or confirming that
you will revise your future proxy disclosures in accordance with the topics discussed below. 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.
Definitive Proxy Statement on Schedule 14A
Pay Versus Performance, page 65
1.We note that you have included Revenue as your Company-Selected Measure pursuant to
Item 402(v)(2)(vi) of Regulation S-K. Please include your Company-Selected Measure in
the Tabular List provided pursuant to Item 402(v)(6) of Regulation S-K. In that regard, we
note that you included “Organic Revenue” in your Tabular List, but not Revenue.
August 9, 2024
Page 2
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 Laura Nicholson at 202-551-3584 or Amanda Ravitz at 202-551-3412 with
any questions.
Sincerely,
Division of Corporation Finance
Disclosure Review Program