United States securities and exchange commission logo
October 19, 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
October 12, 2023
File No. 001-14370
Dear Daniel Dom nguez:
We have reviewed your October 12, 2023 response to our comment
letter and have the
following comments.
Please respond to this letter 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 a
comment applies to your facts and circumstances, please tell us why in
your response.
After reviewing your response to this letter, we may have
additional comments. Unless
we note otherwise, any references to prior comments are to comments in
our September 27,
2023 letter.
Form 20-F for Fiscal Year Ended December 31, 2022
Information on the Company, page 28
1. We note your response
to prior comment 1 and reissue it in part. Please expand your
disclosure to discuss
whether, to date, you have experienced any of the indirect
consequences of
climate-related regulation or business trends noted in our prior comment.
In addition, describe
the internal analyses you utilized to determine that any decreased
demand for goods or
services that produce greenhouse gas emissions or are related to
carbon-based energy
sources would not have a material adverse effect on your operations
or results of
operations, and provide support for your determination of materiality. Explain
how this internal
analysis also supports your belief that an increase in demand for goods
that result in lower
emissions than competing products from precious metal mining
companies could lead to
an increase in demand for your products. Please also discuss the
potential downsides you
reference that may result from increased competition to develop
Daniel Dom nguez
Buenaventura Mining Company Inc.
October 19, 2023
Page 2
innovative new products that results in lower emissions and your basis
for stating that
such downsides would likely have a marginal effect.
2. Your response to prior comment 1 states that you have not had any
material reputational
risk resulting from your operations or products that produce
greenhouse gas emissions.
Please expand your disclosure to discuss the potential adverse
consequences to your
reputation resulting from your operations that produce greenhouse gas
emissions.
3. We note your response to prior comment 2 and reissue it in part.
Please explain how you
considered providing disclosure regarding the potential impact of UV
radiation on your
operations and results, including the cost of the remediation efforts
discussed in your
response. Please also revise your disclosure to discuss how your
operations and results
could be affected to the extent your customers or suppliers are
impacted by severe
weather.
In addition, please tell us the cost of all weather-related damages to
your property or
operations, and the cost of insurance, in each of the fiscal years
ended December 31, 2022,
2021 and 2020.
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
October 19, 2023 Page 2 Office of Energy
& Transportation
FirstName LastName