Schedule 14A
Please expand upon the role that your Lead Independent Director plays in the leadership of the board. For example, please enhance your disclosure to address whether or not your Lead Independent Director may: • represent the board in communications with shareholders and other stakeholders; • require board consideration of, and/or override your CEO on, any risk matters; or • provide input on design of the board itself.
The purpose of this letter is to respond to the Division of Corporation Finance’s letter dated September 2, 2022 (“Corp Finance Letter”). As requested, we confirm that we will enhance future proxy disclosures in accordance with topics discussed in the Corp Finance Letter as well as to any material developments to Berkshire Hathaway’s risk oversight structure. One letter for all the questions, without numbered answers. Read the reply ↗
Please expand upon how your board administers its risk oversight function. For example, please disclose: • why your board elected to retain responsibility for risk oversight rather than assign oversight to a board committee; • the timeframe over which you evaluate risks (e.g., short-term, intermediate-term, or long-term) and how you apply different oversight standards based upon the immediacy of the risk assessed; •Rest of the question
whether you consult with outside advisors and experts to anticipate future threats and trends, and how often you re-assess your risk environment; • how the board interacts with management to address existing risks and identify significant emerging risks; • whether you have a Chief Compliance Officer and to whom this position reports; and • how your risk oversight process aligns with your disclosure controls and procedures.
See the reply above.
Also in this review: closing letter, 2022-10-03