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December 11, 2007
Via U.S. Mail and Facsimile (212-310-3572)
Steven C. Patrick
Chief Financial Officer
Colgate-Palmolive Company
300 Park Avenue
New York, New York 10022
Re: Colgate-Palmolive Company
Form 10-K for Fiscal Year Ended December 31, 2006
Filed February 23, 2007
File No. 1-00644
Dear Mr. Patrick:
We have limited our review of your above filings to
disclosure
relating to your contacts with countries that have been identified
as
state sponsors of terrorism, and we have the following comments.
Our
review with respect to this issue does not preclude further review
by
the Assistant Director group with respect to other issues. At
this
juncture, we are asking you to provide us with supplemental
information, so that we may better understand your disclosure.
Please be as detailed as necessary in your response. After
reviewing
this information, we may raise additional comments.
Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your
filings.
We look forward to working with you in these respects. We welcome
any questions you may have about our comments or on any other
aspect
of our review. Feel free to call us at the telephone numbers
listed
at the end of this letter.
General
1. We are aware of a May 2007 news report indicating that your
products are sold in Cuba. In addition, we note that until very
recently nationals of Cuba, Iran, North Korea, Sudan, and Syria
could
obtain product-related information and "notifications about
special
offers, product news and other communications from Colgate" from a
pull-down menu available in the "Contact Us" section of your
website.
The named countries are identified by the State Department as
state
sponsors of terrorism, and are subject to U.S. economic sanctions
and
export controls. Your Form 10-K does not include any information
regarding contacts with those countries. Please describe to us
the
nature and extent of your past, current, and anticipated contacts
with those countries, if any, whether through distributors or by
other direct or indirect arrangements. Your response should
describe
in reasonable detail the products you have provided into the
referenced countries, whether directly or indirectly, and any
agreements, commercial arrangements, or other contacts with the
governments of those countries or entities controlled by them.
2. Please discuss the materiality of any contacts described in
response to the foregoing comment, and whether they would
constitute
a material investment risk for your security holders. You should
address materiality in quantitative terms, including the
approximate
dollar amounts of any associated revenues, assets, and liabilities
for the last three years concerning each referenced country.
Also,
address materiality in terms of qualitative factors that a
reasonable
investor would deem important in making an investment decision,
including the potential impact of corporate activities upon a
company`s reputation and share value.
We note, for example, that Arizona and Louisiana have adopted
legislation requiring their state retirement systems to prepare
reports regarding state pension fund assets invested in, and/or
permitting divestment of state pension fund assets from, companies
that do business with countries identified as state sponsors of
terrorism. The Missouri Investment Trust has established an
equity
fund for the investment of certain state-held monies that screens
out
stocks of companies that do business with U.S.-designated state
sponsors of terrorism. The Pennsylvania legislature has adopted a
resolution directing its Legislative Budget and Finance Committee
to
report annually to the General Assembly regarding state funds
invested in companies that have ties to terrorist-sponsoring
countries. Florida requires issuers to disclose in their
prospectuses any business contacts with Cuba or persons located in
Cuba. States including California, Connecticut, Maine, New
Jersey,
and Oregon have adopted, and other states are considering,
legislation prohibiting the investment of certain state assets in,
and/or requiring the divestment of certain state assets from,
companies that do business with Sudan. Harvard University,
Stanford
University, the University of California, and other academic
institutions have adopted policies prohibiting investment in,
and/or
requiring divestment from, companies that do business with Sudan.
Your materiality analysis should address the potential impact of
the
investor sentiment evidenced by such actions directed toward
companies that have business contacts with Cuba, Iran, North
Korea,
Sudan, and Syria.
Your qualitative materiality analysis also should address whether,
and the extent to which, the governments of the referenced
countries,
or persons or entities controlled by those governments, receive
cash
or act as intermediaries in connection with your business
contacts.
* * * * *
Please respond to these comments within 10 business days or
tell us when you will provide us with a response. Please submit
your
response letter on EDGAR.
We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filings to be certain that the
filings include all information required under the Exchange Act of
1934 and that they have provided all information investors require
for an informed investment decision. Since the company and its
management are in possession of all facts relating to the
company`s
disclosure, they are responsible for the accuracy and adequacy of
the
disclosures they have made.
In connection with responding to our comments, please
provide,
in writing, a statement from the company acknowledging that:
* the company is responsible for the adequacy and accuracy of the
disclosure in the filings;
* staff comments or changes to disclosure in response to staff
comments do not foreclose the Commission from taking any action
with
respect to the filings; and
* the company may not assert staff comments as a defense in any
proceeding initiated by the Commission or any person under the
federal securities laws of the United States.
In addition, please be advised that the Division of
Enforcement
has access to all information you provide to the staff of the
Division of Corporation Finance in our review of your filings or
in
response to our comments on your filings.
Please understand that we may have additional comments after
we
review your response to our comments. Please contact Pradip
Bhaumik,
Attorney-Advisor, at (202) 551-3333 if you have any questions
about
the comments or our review. You may also contact me at (202) 551-
3470.
Sincerely,
Cecilia Blye, Chief
Office of Global Security
Risk
cc: Pamela Long
Assistant Director
Division of Corporation Finance
Steven C. Patrick
Colgate-Palmolive Company
December 11, 2007
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