AMEAmetek

Please expand your discussion to address the reasons you believe that your leadership structure is appropriate, addressing your specific characteristics or circumstances. In your discussion, please also address how the experience of your Lead Independent Director is brought to bear in connection with your board’s role in risk oversight.

We received your comment letter dated September 20, 2022 (the “Staff Letter”) regarding the Registrant’s Definitive Proxy Statement on Schedule 14A, filed March 14, 2022, for the Annual Meeting of Stockholders held on May 5, 2022 (the “2022 Proxy Statement”). The Registrant respectfully believes that its disclosures under “Corporate Governance⸺Board Leadership Structure” and “Corporate Governance⸺Risk Oversight” in the 2022 Proxy Statement are responsive to Item 407(h) of Regulation S-K.

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Still, in response to the Staff Letter, the Registrant hereby confirms that the Registrant will be certain to consider and, as applicable, address, the topics raised in the Staff Letter, as well as any material developments to the Company’s risk oversight structure, when drafting its future proxy disclosure.

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Please expand upon the role that your Lead Independent Director plays in the leadership of the board. For example, please enhance your disclosure to address whether or not your Lead Independent Director may: • represent the board in communications with shareholders and other stakeholders; • require board consideration of, and/or override your CEO on, any risk matters; or • provide input on design of the board itself.

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Please expand upon how your board administers its risk oversight function. For example, please disclose: • the timeframe over which you evaluate risks (e.g., short-term, intermediate-term, or long-term) and how you apply different oversight standards based upon the immediacy of the risk assessed; • whether you consult with outside advisors and experts to anticipate future threats and trends, and how often you

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re-assess your risk environment; • whether you have a Chief Compliance Officer and to whom this position reports; and • how your risk oversight process aligns with your disclosure controls and procedures.

See the reply above.