United States securities and exchange commission logo
August 25, 2023
Daniel Dom nguez
Chief Financial Officer
Buenaventura Mining Company Inc.
Las Begonias 415 Floor 19
San Isidro, Lima 27, Peru
Re: Buenaventura Mining
Company Inc.
Form 20-F for the
Fiscal Year Ended December 31, 2022
Filed May 1, 2023
File No. 001-14370
Dear Daniel Dom nguez:
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 20-F for the Fiscal Year Ended December 31, 2022
General
1. We note that you
provided more expansive disclosure in your 2021 Sustainability
Report and 2022
Integrated Annual 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 these reports.
Information on the Company, page 28
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;
Daniel Dom nguez
Buenaventura Mining Company Inc.
August 25, 2023
Page 2
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.
3. We note your disclosure on page 15 of your Form 20-F regarding the
physical impact
climate change may have in the regions where your operations are
located. We further
note your disclosure on page 25 of your Form 20-F that multiple global
studies have
consistently highlighted Peru as one of the nations most susceptible
to the adverse effects
of climate change and water scarcity. Discuss in greater detail the
physical effects of
climate change on your operations and results. This disclosure may
include the following:
severity of weather, such as hurricanes, sea levels, arability of
farmland, extreme
fires, and water availability and quality;
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;
decreased agricultural production capacity in areas affected by
drought or other
weather-related changes; and
any weather-related impacts on the cost or availability of
insurance.
Your response should include quantitative information for each of the
periods for which
financial statements are presented in your Form 20-F and explain
whether changes are
expected in future periods.
4. If material, please discuss any purchase or sale of carbon credits or
offsets and the effects
on your business, financial condition, and results of operations. To
the extent applicable,
ensure you provide quantitative information with your response for
each of the periods for
which financial statements are presented in your Form 20-F 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.
Please contact Michael Purcell at 202-551-5351 or Karina Dorin at
202-551-3763 with
any questions.
FirstName LastNameDaniel Dom nguez Sincerely,
Comapany NameBuenaventura Mining Company Inc.
Division of
Corporation Finance
August 25, 2023 Page 2 Office of Energy
& Transportation
FirstName LastName