SYYSysco

Please disclose in greater detail the specific types of corporate office and shared service operations expenses (not allocated to your segments) that are included in the Global Support Center reconciling line item. Refer to ASC 280-10-50-29(b) and 50-31.

Rest of the question

Exhibit 99.1 Sysco Reports Second Quarter Fiscal Year 2025 Results, page 1 You discuss the changes in EBITDA and adjusted EBITDA in the key financial results for the second quarter of fiscal year 2025 without disclosing the change in their most directly comparable GAAP measure, net earnings. Please revise to disclose the change in net earnings with equal or greater prominence. Refer to Item 10(e)(1)(i)(A) 2. of Regulation S-K and Question 102.10(a) of the Non-GAAP Financial Measures Compliance and Disclosure Interpretations. Non-GAAP Reconciliation Net Debt to Adjusted EBITDA, page 23 3. Please disclose the reasons why management believes that presentation of debt/net debt to adjusted EBITDA ratios provides useful information to investors. Also, present and/or discuss debt/net debt to net earnings ratios with equal or greater prominence, when you present and/or discuss debt/net debt to adjusted EBITDA ratios. Refer to Item 10(e)(1)(i)(A) and (C) of Regulation S-K and Question 102.10(a) of the Non-GAAP Financial Measures Compliance and Disclosure Interpretations. 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 respectfully acknowledges the Staff’s comment. The Company advises the Staff that in future filings (including the Company’s next quarterly report on Form 10-Q), the Company will disclose the specific types of corporate office and shared service operation expenses that are included in the Global Support Center reconciling line item. Such disclosure will conform with ASC paragraphs ASC 280-10-50-29(b) and ASC 280-10-50-31.

Rest of the answer

The following is an example of the intended disclosure:

The accounting policies for the segments are the same as those disclosed by Sysco for its consolidated financial statements. Our Global Support Center expenses generally include all expenses of the corporate office and Sysco’s shared service operations. Collectively, our Global Support Center provides numerous centralized services to our operating sites and performs support activities for employees, suppliers and customers. These services include customer and vendor contract administration, finance, legal, information technology, risk management and insurance, sales and marketing, merchandising, inbound logistics, human resources, and strategy. Expenses for the Global Support Center primarily consist of payroll costs for employees assigned to these operations, including severance, if any, all U.S. share-based compensation costs, and certain information technology, self-insurance, and depreciation expenses.

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