Amazon.com (AMZN) CORRESPCorrespondence with SEC

defined in the Prospectus Supplement filed on May 12, 2021 pursuant to Rule 424(b)(2)) was oversubscribed, resulting in a lower interest rate, but the lower interest rate on the Sustainability Notes is not material to our liquidity or financial results.

We also confirm that investors, lenders, and others expressing interest in climate change matters have generally been supportive of our initiatives. As discussed on page 14 of our definitive proxy statement filed on April 15, 2021, we meet regularly with our shareholders to discuss business strategy, performance, compensation philosophy, corporate governance, and environmental and social topics—including climate change and related issues. This is complemented by additional periodic touchpoints with investors, lenders, employees, customers, and other stakeholders by our Investor Relations, ESG Engagement, Public Relations, Sustainability, or other teams in response to inquiries by these stakeholders. We have taken our engagement with such parties into consideration when concluding that any reputational risks with respect to our operations and products that produce greenhouse gas emissions have not been material to our business or financial results or to the market for our securities.

In connection with preparation of our annual report on Form 10-K and each quarterly report on Form 10-Q, our disclosure controls and procedures include a review of risk factors with business, finance, and legal leaders, including in our Sustainability group. As a technology company that seeks to constantly invent, the challenges and risks associated with fulfilling The Climate Pledge to date have not been materially greater or different than those we face in achieving our other business and operational objectives. In assessing this, we evaluate the specific goals and initiatives that we have announced to date and the science and resources that are available or that are needed to reach the goal, as well as our progress to date. For example, using a science-based approach that combines lab testing, machine learning, materials science, and manufacturing partnerships to scale sustainable change across our packaging supply chain, we have reduced the need for additional packaging and improved the design and materials used for our packaging assortment, reducing the weight of packaging materials while making our packaging more robust. Similarly, we believe that addressing business needs through agreements with Rivian and Stellantis for electric vehicles, through our renewable energy purchase contracts, and numerous other initiatives across our operations, have helped suppliers obtain the funding and scale needed to pursue technological advances that will support our Climate Pledge goals.

Through our risk factor review process, we took into account the increasing number of specific initiatives that we have announced, and recognized that a number of them are dependent on developments by third parties, and that even once our current initiatives are fully operational, progress could be limited by technological restrictions and other factors. To address those risks, we included language in the Risk Factors section of our Annual Report on Form 10-K for the year ended December 31, 2021 stating that our sustainability initiatives may be unsuccessful for a

variety of reasons, including if we are unable to realize the expected benefits of new technologies or if we do not successfully plan or execute new strategies.