KOCoca-Cola

Please expand your discussion to address how the experience of the Lead Independent Director is brought to bear in connection with your board’s role in risk oversight.

The Coca-Cola Company (the “Company”) submits this letter to respond to the comments of the staff of the Division of Corporation Finance of the United States Securities and Exchange Commission contained in your letter dated September 2, 2022, regarding your review of the Company’s most recent definitive proxy statement. The Company confirms it will enhance its future proxy disclosures as requested by your comments, as appropriate. If you have any questions or would like further information, please do not hesitate to let me know. 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 the design of the board

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itself.

See the reply above.

Please expand upon how your board administers its risk oversight function. For example, please disclose: • 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; • whether you consult with outside advisors and experts to anticipate future threats and trends, and how often you

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re-assess your risk environment; • how the board interacts with management to identify significant emerging risks; • to whom the Chief Ethics and Compliance Officer reports; and • how your risk oversight process aligns with your disclosure controls and procedures.

See the reply above.