Schedule 14A
Please expand your discussion of the reasons you believe that your leadership structure is appropriate, addressing your specific characteristics or circumstances. In your discussion, please also address how the experience of the Lead Independent Director is brought to bear in connection with your board’s role in risk oversight.
Comcast Corporation (the “Company,” or “we,” “our” or “us”) acknowledges receipt of the comment letter of the Staff of the U.S. Securities and Exchange Commission (the “Staff”) dated September 2, 2022 relating to the Company’s Definitive Proxy Statement on Schedule 14A filed April 22, 2022. We confirm that we will enhance our future proxy disclosures in accordance with the topics discussed in the Staff’s comment letter, to the extent applicable. One letter for all the questions, without numbered answers. Read the reply ↗
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.
See the reply above.
Please expand upon how your board administers its risk oversight function. For example, please disclose: • why your board elected to retain direct oversight responsibility for core enterprise risks, 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 theRest of the question
immediacy of the risk assessed; • 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; • to whom your Chief Compliance Officer reports; and • how your risk oversight process aligns with your disclosure controls and procedures.
See the reply above.
Also in this review: closing letter, 2022-10-18