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                              August 31, 2023

       Karsten Munk Knudsen
       Executive Vice President and Chief Financial Officer
       NOVO NORDISK A/S
       Novo Alle 1
       DK-2880 Bagsv  rd
       Denmark

                                                        Re: NOVO NORDISK A/S
                                                            Form 20-F for the
fiscal year ended December 31, 2022
                                                            Filed February 1,
2023
                                                            File No. 333-82318

       Dear Karsten Munk Knudsen:

              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 20-F for the fiscal year ended December 31, 2022

       General

   1.                                                   We note that you
provided more expansive disclosure in your Annual Report 2022, CDP
                                                        Climate Change 2022
Report, CDP Water Security 2022 Report and on your website 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 such reports and on
your website.
       Operating and Financial Review and Prospects, page 10

   2.                                                   You indicate in your
CDP Climate Change 2022 Report that climate-related risks are
                                                        identified and assessed
through your risk management process. To the extent material,
                                                        discuss the indirect
consequences of climate-related regulation or business trends, such as
                                                        the following:
 Karsten Munk Knudsen
NOVO NORDISK A/S
August 31, 2023
Page 2
                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;
                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.       We note your disclosure on page 23 of your 2022 Annual Report stating
that you "work to
         identify, assess and mitigate short-, medium- and long-term climate
related risks within
         our operations and supply chain, such as flooding, storm surges,
earthquakes, tornadoes
         and wildfires that could disrupt production." 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.
4.       If material, please discuss any purchase or sale of carbon credits or
offsets and the effects
         on your business, financial condition, and results of operations. To
the extent applicable,
         ensure you provide quantitative information with your response for
each of the periods for
         which financial statements are presented in your Form 20-F and for any
future periods.
        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 Anuja A. Majmudar, Attorney-Adviser, at (202) 551-3844 or
Karina
Dorin, Attorney-Adviser, at (202) 551-3763 with any questions.



FirstName LastNameKarsten Munk Knudsen                         Sincerely,
Comapany NameNOVO NORDISK A/S
                                                               Division of
Corporation Finance
August 31, 2023 Page 2                                         Office of Life
Sciences
FirstName LastName