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United States securities and exchange commission logo
August 25, 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
Filed February 4,
2022
File No. 001-03492
Dear Mr. Carre:
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 December 31, 2021
General
1. We note that you
provided more expansive disclosure in your 2021 Annual
& Sustainability 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 Annual & Sustainability Report.
Risk Factors, page 9
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 credit risks or
technological changes.
3. Disclose any material
litigation risks related to climate change and explain the potential
impact to the company.
Eric Carre
FirstName
HalliburtonLastNameEric Carre
Company
Comapany
August 25, NameHalliburton
2022 Company
August
Page 2 25, 2022 Page 2
FirstName LastName
Management's Discussion and Analysis of Financial Condition and Results of
Operations, page
21
4. We note your goal to reduce your carbon footprint and the
environmental impact of your
operations on page 22 of your Form 10-K. Please revise your disclosure
to identify any
material past and/or future capital expenditures for climate-related
projects. Provide
quantitative information for each of the periods for which financial
statements are
presented in your Form 10-K and for any future periods as part of your
response.
5. To the extent material, please discuss the indirect consequences of
climate-related
regulation or business trends as they relate to your services and
products, 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 or services that result in lower
emissions than competing
products;
increased competition to develop innovative new products that
result in lower
emissions (e.g., low-carbon solutions); and
any anticipated reputational risks resulting from your operations
or products that
produce material greenhouse gas emissions.
6. We note your disclosure on page 10 of your Form 10-K regarding the
effect of global
climate change on weather conditions. If material, please revise your
disclosure to include
the following:
quantification of material 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
any weather-related impacts on the cost or availability of
insurance.
Your response should include quantitative information for each of the
periods covered by
your Form 10-K.
7. We note your disclosures on pages 13 and 14 of your Form 10-K
regarding compliance
with environmental laws and regulations. Please tell us about and
quantify compliance
costs related to climate change for each of the periods for which
financial statements are
presented in your Form 10-K and whether increased amounts are expected
to be incurred
in future periods.
8. If material, provide disclosure about your purchase or sale of carbon
credits or offsets and
any material effects on your business, financial condition, or results
of operations. Please
ensure you provide quantitative information with your response for
each of the periods
covered by your Form 10-K and for any future periods.
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.
Eric Carre
Halliburton Company
August 25, 2022
Page 3
Please contact Michael Purcell at 202-551-5351 or Karina Dorin at
202-551-3763 with
any questions.
FirstName LastNameEric Carre Sincerely,
Comapany NameHalliburton Company
Division of
Corporation Finance
August 25, 2022 Page 3 Office of Energy &
Transportation
FirstName LastName