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United States securities and exchange commission logo
June 24, 2022
Kirsten Spears
Chief Financial Officer
Broadcom Inc.
1320 Ridder Park Drive
San Jose, CA 95131
Re: Broadcom Inc.
Form 10-K for
Fiscal Year Ended October 31, 2021
Filed December 17,
2021
File No. 001-38449
Dear Ms. Spears:
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 for Fiscal Year Ended October 31, 2021
General
1. We note that you
provided more expansive disclosure in your Environmental, Social
& Governance Report (
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.
Risk Factors, page 13
2. Disclose the material
effects of transition risks related to climate change that may affect
your business,
financial condition, and results of operations, such as policy and regulatory
changes that could
impose operational and compliance burdens, market trends that may
alter business
opportunities, credit risks, or technological changes.
3. Disclose any material
litigation risks related to climate change and explain the potential
Kirsten Spears
FirstName LastNameKirsten Spears
Broadcom Inc.
Comapany
June NameBroadcom Inc.
24, 2022
June 24,
Page 2 2022 Page 2
FirstName LastName
impact to the company.
Management's Discussion and Analysis of Financial Condition and Results of
Operations, page
35
4. It appears you have identified climate-related projects in your ESG
Report, such as
projects to save energy and reduce greenhouse gas emissions. Tell us
how you considered
providing disclosure regarding past and future capital expenditures
for climate-related
projects. Include quantitative information for the periods covered by
your Form 10-K and
for future periods as part of your response.
5. We note your risk factor disclosure on page 26 regarding social and
environmental
responsibility regulations, policies and provisions as well as
customer and investor
demands. Tell us how you considered providing disclosure regarding the
indirect
consequences of climate-related regulation or business trends in
particular, 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 anticipate reputational risk resulting from operations or
products that produce
material greenhouse gas emissions; and
potential climate-related opportunities, such as the development
of new products or
services and the increased requirements for high performance and
low power
products.
6. 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;
weather-related impacts on the cost and availability of insurance;
quantification of any weather-related damages to your property or
operations; and
the potential for indirect weather-related impacts that have
affected or may affect
your major customers.
Include quantitative information with your response for each of the
periods covered by
your Form 10-K and explain whether increased amounts are expected in
future periods.
7. We note your disclosure on page 26 regarding the costs to comply with
environmental
regulations. Tell us about and quantify any compliance costs related
to climate change for
each of the last three fiscal years and explain whether increased
amounts are expected to
be incurred in future periods.
Kirsten Spears
Broadcom Inc.
June 24, 2022
Page 3
8. If material, please provide disclosure about any purchase or sale of
carbon credits or
offsets and any material effects on your business, financial
condition, and results of
operations. Include quantitative information for each of the periods
for which financial
statements are presented in your Form 10-K and for future periods as
part of your
response.
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 Erin Donahue at 202-551-6063 or Sergio Chinos at
202-551-7844 with
any questions.
FirstName LastNameKirsten Spears Sincerely,
Comapany NameBroadcom Inc.
Division of
Corporation Finance
June 24, 2022 Page 3 Office of
Manufacturing
FirstName LastName