United States securities and exchange commission logo
September 27, 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
Response dated
September 11, 2023
File No. 001-14370
Dear Daniel Dom nguez:
We have reviewed your September 11, 2023 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
August 25, 2023 letter.
Form 20-F for the Fiscal Year Ended December 31, 2022
Information on the Company, page 28
1. We note your response
to prior comment 2 and reissue the comment as it does not appear
that each of the items
identified in our prior comment is addressed in your response.
Please provide us with
your analysis of the indirect consequences of climate-related
regulation or business
trends, including each of 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;
Daniel Dom nguez
Buenaventura Mining Company Inc.
September 27, 2023
Page 2
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.
Please ensure your response explains how you assessed each potential
indirect
consequence and how you concluded on materiality for the items for
which disclosure was
not deemed necessary.
2. We note your response to prior comment 3 and reissue it in part.
Please discuss in greater
detail the physical effects of climate change on your operations and
results and how you
considered providing disclosure regarding:
the potential impact of UV radiation;
the potential for indirect weather-related impacts that have
affected or may affect
your major customers or suppliers; and
decreased agricultural production capacity in areas affected by
drought or other
weather related changes.
In addition, quantify weather-related damages to your property or
operations and the cost
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.
3. We note your response to prior comment 4 and reissue it in part.
Please tell us whether
you expect to purchase carbon credits or offsets in 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
September 27, 2023 Page 2 Office of Energy
& Transportation
FirstName LastName