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United States securities and exchange commission logo
July 31, 2023
David S. Schulz
Chief Financial Officer
WESCO International, Inc.
225 West Station Square Drive
Suite 700
Pittsburgh, PA 15219
Re: WESCO
International, Inc.
Form 10-K for
Fiscal Year Ended December 31, 2022
Filed February 21,
2023
File No. 001-14989
Dear David S. Schulz:
We have reviewed your July 10, 2023 response to our comment
letter 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 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.
Unless we note otherwise, our references to prior comments are to
comments in our June 26,
2023 letter.
Form 10-K for Fiscal Year Ended December 31, 2022
Management's Discussion and Analysis
Results of Operations, page 27
1. We note your response
to comment one and your proposed revised disclosure. Please
revise to quantify
expense amounts by segment and to provide separate discussion and
analysis for each
segment, rather than quantifying only the change in the expense amounts
and discussing them
together. Please consider whether presenting segment results in
tabular form, organized
by reportable segment, would aid financial statement users, with
narrative text
refocused on discussing and analyzing results in the tables rather than on
stating amounts in
tables.
David S. Schulz
WESCO International, Inc.
July 31, 2023
Page 2
2. We note your response to comment two and your revised explanation of
value-driven
pricing. If correct, consider whether a plain English description as
"price increases"
would be more appropriate. In addition, the explanation of
value-driven pricing (or "price
increases") appears to be a factor driving changes in sales rather
than cost of sales directly.
3. We note your response to comment three and your proposed revised
disclosure. In your
response you state you cannot precisely quantify the impact that
changes in prices or
volume had on the change in net sales. However, in your fourth quarter
2022 earnings
call, you stated:
you estimate pricing added approximately 6 points to sales
growth, with the benefit
primarily in your UBS and EES businesses (8% for the year);
your ability to cross-sell Wesco and Anixter products and
services contributed more
than $260 million of sales in the quarter ($850 million for the
year); and
higher supplier volume rebates in the quarter provided a
40-basis-point benefit.
Please reconcile these disclosures with your response. In your filing
you disclose that net
sales increased primarily due to "price inflation and volume growth,
secular demand
trends, and execution of our cross-sell program." Please tell us how
you know these were
the primary factors affecting your results. We also note that you
disclose pricing "related
to inflation" impacted net sales by 8%. Please tell us whether this
factor includes the
effect of all pricing changes on net sales or just a portion
attributable to inflation. If it
includes all pricing changes, please tell us why you are unable to
quantify this factor in
absolute dollars nor compute the remaining change (after other
quantified factors) due to
volume. If it does not include all pricing changes, please tell us how
you were able to
measure or estimate this portion of the change in price but not other
portions, and how this
portion is measured.
Please direct any questions to Amy Geddes at 202-551-3304 or Lyn Shenk
at 202-551-
3380.
FirstName LastNameDavid S. Schulz Sincerely,
Comapany NameWESCO International, Inc.
Division of
Corporation Finance
July 31, 2023 Page 2 Office of Trade
& Services
FirstName LastName