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United States securities and exchange commission logo
June 2, 2022
David Looney
Chief Financial Officer
Murphy Oil Corporation
9805 Katy Fwy, Suite G-200
Houston, Texas 77024
Re: Murphy Oil
Corporation
Form 10-K for
Fiscal Year Ended December 31, 2021
Filed February 25,
2022
File No. 001-08590
Dear Mr. Looney:
We have reviewed your filing and have the following comments. In
some of our
comments, we may ask you to provide us with information so we may better
understand your
disclosure.
Please respond to these comments within ten business days by
providing the requested
information or advise us as soon as possible when you will respond. If
you do not believe our
comments apply to your facts and circumstances, please tell us why in
your response.
After reviewing your
response to these comments, we may have additional comments.
Form 10-K Filed February 25, 2022
General
1. We note that you
provided more expansive disclosure in your Sustainability Report than
you provided in your
SEC filings. Please advise us what consideration you gave to
providing the same type
of climate-related disclosure in your SEC filings as you provided
in your Sustainability
Report.
Risk Factors, page 15
2. It appears that you
have identified demand for less carbon intensive energy sources and
the technological
advancement of non-fossil-fuel energy sources as transition risks related
to climate change.
Please expand your disclosure to address the effects of these transition
risks on your business,
financial condition, and results of operations in greater detail.
Additionally, tell us
about other transition risks related to climate change, such as market
trends that may alter
business opportunities and credit risks, and explain how you
David Looney
FirstName
Murphy OilLastNameDavid
Corporation Looney
Comapany
June 2, 2022NameMurphy Oil Corporation
June 2,
Page 2 2022 Page 2
FirstName LastName
considered providing related disclosure in your SEC filings.
3. Disclose any material litigation risks related to climate change and
explain the potential
impact to the company.
Management's Discussion and Analysis of Financial Condition and Results of
Operations, page
32
4. We note from the disclosure on page 48 of your Form 10-K that you
allocate a portion of
your capital expenditures towards compliance with existing and
anticipated environmental
laws and regulations. We also note the language in your Sustainability
Report regarding
investments you have made and technologies you have implemented to
reduce greenhouse
gas and other emissions. Please revise your disclosure to identify any
material past and/or
future capital expenditures for climate-related projects. Quantify
these expenditures for
each of your last three years and amounts budgeted for future periods
in your response. In
addition, quantify compliance costs incurred related to climate change
for the same
periods.
5. To the extent material, discuss the indirect consequences of
climate-related regulation or
business trends, such as the following:
any anticipated reputational risks resulting from operations or
products that produce
material greenhouse gas emissions;
increased competition to develop innovative new products that
result in lower
emissions; and
developments that create new opportunities such as low-carbon
technologies that
complement your existing assets.
6. We note the disclosure on page 19 regarding your vulnerability to
severe weather. Please
provide additional disclosure discussing the potential for indirect
weather-related impacts
that have affected or may affect your major customers or suppliers.
7. You disclose that weather-related risks are not fully insured. Tell us
more about weather-
related impacts on the availability of insurance and provide us with
quantitative
information regarding the cost of insurance for the last three years
and the current year. In
addition, quantify any weather-related damages to your property or
operations during the
last three years.
8. Tell us how you considered providing disclosure about your purchase or
sale of carbon
credits or offsets. Include quantitative information regarding any
such transactions during
the last three years and subsequent periods with your response.
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.
David Looney
Murphy Oil Corporation
June 2, 2022
Page 3
Please contact Michael Purcell at 202-551-5351 or Ethan Horowitz at
202-551-3311 with
any questions.
FirstName LastNameDavid Looney Sincerely,
Comapany NameMurphy Oil Corporation
Division of
Corporation Finance
June 2, 2022 Page 3 Office of Energy &
Transportation
FirstName LastName