United States securities and exchange commission logo
September 22, 2022
Matthew Galvanoni
Chief Financial Officer and Chief Accounting Officer
Pilgrim's Pride Corporation
1770 Promontory Circle
Greeley, CO 80634-9038
Re: Pilgrim's Pride
Corporation
Form 10-K for the
Year Ended December 26, 2021
Filed February 18,
2022
Form 10-Q for the
Period Ended June 26, 2022
Filed July 28, 2022
File No. 001-09273
Dear Mr. Galvanoni:
We have limited our review of your filing to the financial
statements and related
disclosures 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-Q for the Period Ended June 26, 2022
Item 2. Management's Discussion and Analysis of Financial Condition and
Results of
Operations, page 33
1. Please disclose in
future filings whether and how your business segments, products, lines
of service, projects,
or operations are materially impacted by supply chain disruptions,
especially in light of
Russia s invasion of Ukraine. For example, discuss whether you
have or expect to:
suspend the
production, purchase, sale or maintenance of certain items;
experience higher
costs due to constrained capacity or increased commodity prices or
challenges
sourcing materials [(e.g., nickel, palladium, neon, cobalt, iron, platinum or
other raw material
sourced from Russia, Belarus, or Ukraine)];
experience surges
or declines in consumer demand for which you are unable to
Matthew Galvanoni
Pilgrim's Pride Corporation
September 22, 2022
Page 2
adequately adjust your supply; or
be unable to supply products at competitive prices or at all due
to export restrictions,
sanctions, or the ongoing invasion; or
be exposed to supply chain risk in light of Russia s invasion of
Ukraine and/or related
geopolitical tension or have sought to de-globalize your
supply chain.
Explain whether and how you have undertaken efforts to mitigate the
impact and where
possible quantify the impact to your business.
2. Please disclose in future filings any known trends or uncertainties
that have had or are
reasonably likely to have a material impact on your cash flows,
liquidity, capital
resources, cash requirements, financial position, or results of
operations arising from,
related to, or caused by the global disruption from, Russia s
invasion of Ukraine. Trends
or uncertainties may include impairments of financial assets or
long-lived assets; declines
in the value of inventory, investments, or recoverability of deferred
tax assets; the
collectability of consideration related to contracts with customers;
and modification of
contracts with customers.
Part II. Other Information
Item 1A. Risk Factors, page 50
3. We note there may be increased risk of cyberattacks as a result of the
ongoing Russia-
Ukraine war. To the extent material, please disclose any new or
heightened risk of
potential cyberattacks by state actors or others since Russia s
invasion of Ukraine and
whether you have taken actions to mitigate such potential risks.
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.
You may contact Jeffrey Gordon at 202-551-3866 or Jean Yu at
202-551-3305 with any
questions.
FirstName LastNameMatthew Galvanoni Sincerely,
Comapany NamePilgrim's Pride Corporation
Division of
Corporation Finance
September 22, 2022 Page 2 Office of
Manufacturing
FirstName LastName