United States securities and exchange commission logo
October 19, 2022
Eric Carre
Executive Vice President, Chief Financial Officer
Halliburton Company
3000 North Sam Houston Parkway East
Houston, TX 77032
Re: Halliburton Company
Form 10-K for
Fiscal Year Ended December 31, 2021
Response dated
October 4, 2022
File No. 001-03492
Dear Eric Carre:
We have reviewed your October 4, 2022 response to our comment
letter 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. Unless we note otherwise, our references to prior comments are
to comments in our
September 21, 2022 letter.
Response dated October 4, 2022
Management's Discussion and Analysis of Financial Condition and Results
of Operations, page
21
1. We note your response
to prior comment 2 states that you monitor public perception of the
Company and its
reputation and that some of your stakeholders are interested in learning
more about your
ESG-related goals. However, your response does not address any
anticipated
reputational risks resulting from your operations or products that produce
greenhouse gas
emissions. Please tell us what consideration you gave to including
disclosure regarding
any anticipated climate-related reputational risks, including those that
relate to being a
provider of products and services to the energy industry.
Eric Carre
Halliburton Company
October 19, 2022
Page 2
Please contact Michael Purcell at 202-551-5351 or Karina Dorin at
202-551-3763 with
any questions.
Sincerely,
FirstName LastNameEric Carre
Division of
Corporation Finance
Comapany NameHalliburton Company
Office of Energy &
Transportation
October 19, 2022 Page 2
cc: Van Beckwith
FirstName LastName