LyondellBasell Industries N.V.

Response of the Office International Corporate Finance
Division of Corporation Finance

November 15, 2024

Thomas J. Kim
Gibson, Dunn & Crutcher LLP
1700 M Street NW
Washington, DC 20036-4504
   

Re:   LyondellBasell Industries N.V.
          Incoming letter dated November 15, 2024

Dear Mr. Kim:

Based on the facts presented, the Division of Corporation Finance will not object if LyondellBasell Industries N.V. were to file a definitive proxy statement without filing a preliminary proxy statement for the proposals, as described in your incoming letter, that are required to be submitted for shareholder approval at an annual meeting under the laws of the Netherlands. Foreign issuers organized under the laws of the Netherlands may rely on this letter with respect to the proposals described in your incoming letter.

This position is based on the representations made to the Division in your letter. Any different facts or conditions might require the Division to reach a different conclusion.