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United States securities and exchange commission logo
August 14, 2023
David Kabbes
General Counsel
Stepan Company
1101 Skokie Blvd., Suite 500
Northbrook, Illinois 60062
Re: Stepan Company
Annual Report on
Form 10-K
Filed February 28,
2023
File No. 001-04462
Dear David Kabbes:
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.
Annual Report on Form 10-K
General
1. We note that you
provided more expansive disclosure in your 2022 Sustainability Report
and ESG Analyst
Download 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 Sustainability Report and Analyst Download.
Management's Discussion and Analysis of Financial Condition and Results
of Operations, page
21
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;
David Kabbes
Stepan Company
August 14, 2023
Page 2
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.
3. We note discussion in your Sustainability Report addressing weather-
and climate-related
events, water quality and quantity, and potential impacts to your
supply chain and your
facilities. 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 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
the extent to which extreme weather events have reduced the
availability of insurance
or increased the cost of insurance.
Include quantitative information for each of the periods covered by
your Form 10-K and
explain whether increased amounts are expected in future periods.
4. You reference the purchase of Renewable Energy Certificates ( RECs
) or Green Origin
Certificates ( GOs ) in your Sustainability Report. Please provide
disclosure about your
purchase and sale of carbon credits, carbon offsets, RECs, or GOs, and
any material
effects on your business, financial condition, and results of
operations. Provide us with
quantitative information for each of the periods covered by your most
recent Form 10-K
and the amounts budgeted for or expected to be incurred 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.
You may Benjamin Richie at 202-551-7857 or Jennifer Angelini at
202-551-3047 with
any other questions.
Sincerely,
FirstName LastNameDavid Kabbes
Division of
Corporation Finance
Comapany NameStepan Company
Office of
Industrial Applications and
August 14, 2023 Page 2 Services
FirstName LastName