HONHoneywell Technologies

We refer to the realignment, during the first quarter of 2024, of certain of your business units into two new reportable business segments, Industrial Automation and Energy and Sustainability Solutions, and have the following comments: • In regard to the Industrial Automation reportable segment, please tell us in sufficient detail how you determined that the respective operating segments met the aggregation criteria

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upon the addition of the Process Solutions business unit. Refer to ASC 280-10-50-11. • Please tell us whether the change in reportable segments impacted your existing reporting units prior to the realignment. If so, please tell us whether you performed an interim goodwill impairment test related to the existing reporting units before the change. Refer to ASC 350-20-35-3C(f) and ASC 350-20-35-45. In closing, 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.

The Company identifies operating segments in accordance with ASC 280-10-50-1. In October 2023, Honeywell announced plans to realign our business portfolio to three compelling megatrends. As part of this realignment, effective January 2024, the Company changed its organization structure, combining the Process Solutions business unit with the former Safety and Product Solutions business units to form our Industrial Automation segment.

On January 1, 2024, the Company appointed a President and Chief Executive Officer (CEO) of Industrial Automation, reporting directly to the chief operating

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decision maker (CODM). In the first quarter of 2024, the information regularly reviewed by the CODM changed to include the operating results and budget of the Industrial Automation segment and this information is used by the CODM to assess its performance and allocate resources. The compensation structure for the President and CEO of Industrial Automation is partially based on the performance of the Industrial Automation business.

Based on these considerations, the Company identified Industrial Automation as an operating segment and reports information on that operating segment under ASC 280-10-50-10. The Company does not maintain operating segments below Industrial Automation to aggregate. Since it combined the Process Solutions business unit and former Safety and Products Solutions business units collectively together as one new operating segment under ASC 280-10-50-1, the Company was not required to and has not applied the separate aggregation criteria outlined in ASC 280-10-50-11 to the Industrial Automation segment because it was determined to be one operating segment.

Honeywell's realignment during the first quarter of 2024 did not impact the Company's reporting units. The reporting unit composition is unchanged before and after the reorganization. As a result of the realignment, the Process Solutions reporting unit moved to the Industrial Automation segment with no changes in the composition or carrying amount of its net assets. In addition, there were no events or changes in circumstances identified that would more likely than not reduce the fair value of an existing reporting unit below its carrying amount as a result of this move. Therefore, the Company was not required to perform an interim goodwill impairment test.

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We note from your disclosure on page three that you have implemented and continue to identify actions to mitigate the effect of supply chain constraints and rising costs for materials and labor. You also disclose on page eight that you have implemented shortterm and long-term strategies to reduce the impacts of current and future disruptions of the supply chain for certain raw materials.

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In future periodic filings, please provide a more comprehensive discussion explaining the mitigation efforts you have undertaken and discuss known trends or uncertainties resulting from mitigation efforts undertaken, if any. Explain whether any mitigation efforts introduce new material risks, including those related to product quality, reliability, or regulatory approval of products. Please also discuss whether supply chain disruptions materially effect your outlook or business goals. Results of Operations, page 17

The Company acknowledges the Staff’s comment and will include the requested disclosure where relevant in our future Form 10-Q and Form 10-K filings, such as the Raw Materials section of our future Form 10-K filings. Read in the reply ↗

Where you identify two or more factors that contributed to material changes in financial statement line items, please expand your disclosures to quantify the individual impact of each factor; for example, we note you have identified multiple factors contributing to the decrease in revenue for Defense and Space within your Aerospace segment.

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Please note this comment applies to all future periodic reporting as we note similar instances in your Form 10-Q for the period ended June 30, 2022. Please refer to Item 303(a)(3) of Regulation S-K and SEC Release No. 33-8350.

The Company acknowledges the Staff’s comment and, where the disclosure in Management's Discussion and Analysis of Financial Condition and Results of Operations identifies two or more factors that contribute to material changes in financial statement line items, the Company will include disclosures to define the impact of each factor to the applicable financial statements line item in future Form 10-Q and Form 10-K filings. Read in the reply ↗

Given the significance of your foreign operations, please revise future disclosures to quantify the amount of cash and cash equivalents held in foreign jurisdictions as of the most recent period end, and address the potential impact on your liquidity of holding cash outside the U.S.

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Additionally, if your cash is located in various tax jurisdictions with differing tax rates, please expand your liquidity disclosure to address the potential tax consequences (if any) of repatriating cash from foreign tax jurisdictions. To the extent you believe cash is indefinitely reinvested in foreign entities and is not likely to be repatriated for any foreseeable purpose, please disclose that viewpoint.

The Company acknowledges the Staff’s comment and will include the amount of cash and cash equivalents held in foreign jurisdictions and the impact to the Company’s liquidity in the Liquidity and Capital Resources section of our future Form 10-Q and Form 10-K filings. To the extent material, the Company will disclose the potential tax consequences of repatriating cash and cash equivalents held in foreign jurisdictions. Read in the reply ↗

In future filings, please expand your narrative to quantify and more fully discuss the primary reasons for the significant changes in working capital between periods. In this regard we note higher inventory and accounts payable balances. Please explain the underlying factors causing these increases. Refer to Section IV.B.1 of SEC Release No. 33-8350.

The Company acknowledges the Staff’s comment and, where the Company identifies in the Cash Flow Summary significant changes in working capital between periods, the Company will include disclosures to define the impact of the primary factors driving material changes to the Company’s working capital in future Form 10-Q and Form 10-K filings. Read in the reply ↗

We note in the discussion on page one that several non-GAAP financial measures were referenced without any discussions of corresponding GAAP financial measures. Please revise future earnings reports to provide discussions of financial measures on a GAAP basis with equal or greater prominence to the non-GAAP financial measures.

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Refer to Item 10(e)(1)(i)(A) of Regulation S-K and Question 102.10 of the Compliance and Disclosure Interpretations on Non-GAAP Financial Measures.

The Company acknowledges the Staff’s comment and has provided discussions of financial measures on a GAAP basis with equal or greater prominence to the non-GAAP financial measures in the earnings report furnished on Form 8-K for the quarter ended September 30, 2022, and will continue to do so in future earnings reports furnished on Form 8-K. Read in the reply ↗

In your reconciliation of adjusted diluted earnings per share, you present adjustments net of tax. Please revise your reconciliations in future filings to present the tax effects of non- GAAP adjustments as a separate adjustment and provide an explanation of how the tax impacts are calculated. Please refer to Question 102.11 of the Compliance & Disclosures Interpretations on Non-GAAP Financial Measures.

The Company acknowledges the Staff’s comment and has quantified the tax effects of individual non-GAAP adjustments in the footnotes to the reconciliation of Earnings per Share to Adjusted Earnings per Share and has provided an explanation of how the tax impacts are calculated for individual non-GAAP adjustments in the earnings report furnished on Form 8-K for the quarter ended September 30, 2022, and will continue to do so in future earnings reports furnished on Form 8-K as applicable. Read in the reply ↗