United States securities and exchange commission logo
September 15, 2022
Craig A. Lampo
Chief Financial Officer
Amphenol Corporation
358 Hall Avenue
Wallingford, CT 06492
Re: Amphenol
Corporation
Form 10-K for
Fiscal Year Ended December 31, 2021
February 9, 2022
File No. 001-10879
Dear Mr. Lampo:
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 10-K for Fiscal Year Ended December 31, 2021
General
1. We note that you
provided more expansive disclosure in your 2021 Sustainability Report
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 your 2021
Sustainability Report.
Risk Factors, page 14
2. Disclose the material
effects of transition risks related to climate change that may affect
your business,
financial condition, and results of operations, such as market trends that
may alter business
opportunities, credit risks, or technological changes.
3. Disclose any material
litigation risks related to climate change and explain the potential
impact to the company.
Craig A. Lampo
Amphenol Corporation
September 15, 2022
Page 2
Management's Discussion and Analysis of Financial Condition and Results of
Operations, page
27
4. It appears you have identified climate-related projects in your
Sustainability Report.
Please tell us about and quantify past and/or future capital
expenditures for climate-related
projects for each of the periods for which financial statements are
presented in your Form
10-K and those planned for future periods.
5. To the extent material, discuss the indirect consequences of
climate-related regulation or
business trends, such as the following:
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; and
increased demand for generation and transmission of energy from
alternative energy
sources.
Also, disclosure on page 23 of your Form 10-K appears to address
reputational risks
related to regulatory changes surrounding greenhouse gas emissions and
other climate
change-related laws and regulations. Tell us how you considered
providing disclosure
regarding reputational risks as an indirect consequence of
climate-related business trends.
6. We note your disclosure on page 16 regarding the impacts of extreme
weather conditions
and natural disasters, including those caused by climate change.
Please further discuss the
physical effects of climate change on your operations and results,
such as weather-related
damages to your property or operations, and weather-related impacts on
the cost or
availability of insurance. Include quantitative information with your
response for each of
the periods covered by your Form 10-K and explain whether increased
amounts are
expected in future periods.
7. Tell us about and quantify any compliance costs related to climate
change during the
periods for which financial statements are presented in your Form 10-K
and explain
whether increased amounts are expected in future periods.
8. If material, provide disclosure about your purchase or sale of carbon
credits or offsets and
FirstName LastNameCraig A. Lampo
any material effects on your business, financial condition, and results
of operations.
Comapany NameAmphenol
Provide Corporation
us with quantitative information regarding your purchase or
sale of carbon credits
or offsets
September during
15, 2022 the2 last three fiscal years and amounts budgeted for
future periods.
Page
FirstName LastName
Craig A. Lampo
FirstName
Amphenol LastNameCraig A. Lampo
Corporation
Comapany 15,
September NameAmphenol
2022 Corporation
September
Page 3 15, 2022 Page 3
FirstName LastName
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 Patrick Fullem at (202) 551-8337 or Jennifer Angelini at
(202) 551-3047
with any questions.
Sincerely,
Division of
Corporation Finance
Office of
Manufacturing