TEXT-EXTRACT 2 filename2.txt United States securities and exchange commission logo August 25, 2022 Jeffrey L. Tate Executive Vice President and Chief Financial Officer Leggett & Platt, Incorporated No. 1 Leggett Road Carthage, Missouri 64836 Re: Leggett & Platt, Incorporated Form 10-K for Fiscal Year Ended December 31, 2021 Filed February 22, 2022 File No. 001-07845 Dear Mr. Tate: 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 2022 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 2022 Sustainability Report. Risk Factors, page 17 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. Jeffrey L. Tate FirstName LastNameJeffrey Leggett & Platt, IncorporatedL. Tate Comapany August 25, NameLeggett 2022 & Platt, Incorporated August Page 2 25, 2022 Page 2 FirstName LastName 3. Disclose any material litigation risks related to climate change and explain the potential impact to the company. Management's Discussion and Analysis of Financial Condition and Results of Operations, page 31 4. It appears you have identified climate-related projects in your Sustainability Report, such as projects to reduce carbon emissions and energy use. 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. To the extent material, please 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; and any anticipated reputational risks resulting from operations or products that produce material greenhouse gas emissions. 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; quantification of 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. As applicable, provide us with quantitative information in your response for the periods covered by your Form 10-K. 7. Disclosure on page 25 of your Form 10-K states that you have experienced increased property insurance premiums, in part, due to enhanced weather-related risks. Please provide us with quantitative information regarding the weather-related impact on the cost of insurance during the periods for which financial statements are presented in your Form 10-K and tell us about any expected changes in future periods. 8. We note your disclosure on page 56 about compliance costs related to climate change. Please 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. Jeffrey L. Tate Leggett & Platt, Incorporated August 25, 2022 Page 3 9. 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 LastNameJeffrey L. Tate Sincerely, Comapany NameLeggett & Platt, Incorporated Division of Corporation Finance August 25, 2022 Page 3 Office of Manufacturing FirstName LastName