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United States securities and exchange commission logo
September 21, 2021
Robert B. Ford
President and Chief Executive Officer
ABBOTT LABORATORIES
100 Abbott Park Road
Abbott Park, Illinois 60064-6400
Re: ABBOTT LABORATORIES
Form 10-K for the
Fiscal Year Ended December 31, 2020
Filed February 19,
2021
File No. 001-02189
Dear Mr. Ford:
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.
1. We note that you
provided more expansive disclosure in your CSR 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
CSR report.
2. You generally refer to
federal and state environmental protection laws and regulations
concerning emissions
and discharges to the environment from various manufacturing
operations. Please
tailor the general disclosure about pending or existing climate change-
related legislation,
regulations, and international accords to describe the impact to your
business, financial
condition, and results of operations.
Robert B. Ford
FirstName LastNameRobert B. Ford
ABBOTT LABORATORIES
Comapany 21,
September NameABBOTT
2021 LABORATORIES
September
Page 2 21, 2021 Page 2
FirstName LastName
3. To the extent applicable and 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; and
any anticipated reputational risks resulting from operations or
products that produce
material greenhouse gas emissions.
4. If material, discuss the significant physical effects of climate
change on your operations
and results. This disclosure may include the following:
severity of weather, such as floods, hurricanes, extreme fires,
and water availability
and quality;
quantification of any material weather-related damages to your
property or
operations; and
potential for indirect weather-related impacts that have affected
or may affect your
major customers or suppliers.
5. 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.
6. Disclose any material litigation risks related to climate change and
the potential impact to
the company.
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.
You may contact Margaret Schwartz at 202-551-7153 or Christopher Edwards
at 202-
551-6761 with any questions.
Sincerely,
Division of
Corporation Finance
Office of Life
Sciences