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United States securities and exchange commission logo
September 6, 2023
James Kehoe
Chief Financial Officer
Fidelity National Information Services, Inc.
347 Riverside Avenue
Jacksonville, FL 32202
Re: Fidelity National
Information Services, Inc.
Form 10-K for the
Fiscal Year Ended December 31, 2022
Filed February 27,
2023
File No. 001-16427
Dear James Kehoe:
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 for the Fiscal Year Ended December 31, 2022
General
1. We note that you
provided more expansive disclosure in your Global 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 Global
Sustainability Report.
Management's Discussion and Analysis of Financial Condition and Results
of Operations, page
31
2. To the extent material,
discuss the indirect consequences of climate-related regulation or
business trends, such
as the following:
decreased demand
for goods or services that produce significant greenhouse gas
emissions or are
related to carbon-based energy sources;
increased demand
for goods that result in lower emissions than competing products;
James Kehoe
Fidelity National Information Services, Inc.
September 6, 2023
Page 2
increased competition to develop innovative new products that
result in lower
emissions;
increased demand for generation and transmission of energy from
alternative energy
sources; and
any anticipated reputational risks resulting from operations or
products that produce
material greenhouse gas emissions.
3. Discuss the physical effects of climate change on your operations and
results. This
disclosure may include the following:
severity of weather, such as floods, hurricanes, sea levels,
arability of farmland,
extreme fires, and water availability and quality;
quantification of material weather-related damages to your
property or operations;
potential for indirect weather-related impacts that have affected
or may affect your
major customers or suppliers; and
any weather-related impacts on the cost or availability of
insurance.
Your response should include quantitative information for each of the
periods for which
financial statements are presented in your Form 10-K and explain
whether changes are
expected in future periods.
4. We note you disclose in your Global Sustainability Report that you
purchased and retired
carbon credits in the amounts 7,200, 4,363, 0, and 0 scope metric
tonnes CO2 for the years
ended December 31, 2022, 2021, 2020, and 2019 respectively. Please
tell us how you
considered providing disclosure about the purchase of carbon credits
or offsets and any
material effects on your business, financial condition, and results of
operations. Please
also discuss any purchase or sale of carbon credits or offsets in
future periods and ensure
you provide quantitative information 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.
Please contact Michael Purcell at 202-551-5351 or Karina Dorin at
202-551-3763 with
any questions.
FirstName LastNameJames Kehoe Sincerely,
Comapany NameFidelity National Information Services, Inc.
Division of Corporation
Finance
September 6, 2023 Page 2 Office of Energy &
Transportation
FirstName LastName