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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.
Joseph Reitmeier
FirstName LastNameJoseph Reitmeier
Lennox International Inc.
Comapany
August 31, NameLennox
2023 International Inc.
August
Page 2 31, 2023 Page 2
FirstName LastName
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.
Joseph Reitmeier
FirstName LastNameJoseph Reitmeier
Lennox International Inc.
Comapany
August 31, NameLennox
2023 International Inc.
August
Page 3 31, 2023 Page 3
FirstName LastName
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