SNASnap-on

Disclose the material effects of transition risks related to climate change that may affect your business, financial condition, and results of operations, such as policy and regulatory changes that could impose operational and compliance burdens, market trends that may alter business opportunities, credit risks, or technological changes. Item 7

Set forth in this letter are the responses of Snap-on Incorporated (“we,” “our,” “Snap-on,” or “the company”) to the staff’s comments in its letter, dated September 23, 2021, regarding the company’s Form 10-K for the fiscal year ended January 2, 2021 (the “Snap-on 10-K”). All responses are cross-referenced to the numbered comments in the staff’s letter in the order presented. In addition, we have included the text of the comments from that letter.

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Form 10-K for the Fiscal Year Ended January 2, 2021 Disclose the material effects of transition risks related to climate change that may affect your business, financial condition, and results of operations, such as policy and regulatory changes that could impose operational and compliance burdens, market trends that may alter business opportunities, credit risks, or technological changes. We believe we have appropriately disclosed in the Snap-on 10-K the transition risks related to climate change on our businesses, as follows: Environmental and Government Regulations (Page 11) Snap-on is subject to various environmental laws, ordinances, regulations, and requirements of government authorities in the United States and other nations. At Snap-on, these environmental liabilities are managed through the Snap-on Environmental, Health and Safety Management System (“EH & SMS”), which is applied worldwide. The system is based upon continual improvement and is certified to ISO 14001:2015 and OHSAS 18001:2007, verified through Det Norske Veritas (DNV) Certification, Inc. Snap-on believes that it complies with applicable environmental and government requirements in its operations. Expenditures on environmental and governmental matters through EH & SMS have not had, and Snap-on does not for the foreseeable future expect them to have, a material effect upon Snap-on’s capital expenditures, earnings or competitive position. Risk Factors – Legal and Regulatory Risks (Page 20) Our operations expose us to the risk of environmental liabilities, costs, litigation and violations that could adversely affect our financial condition, results of operations and reputation. Certain of our operations are subject to environmental laws and regulations in the jurisdictions in which they operate, which impose limitations on the discharge of pollutants into the ground, air and water and establish standards for the generation, treatment, use, storage and disposal of hazardous wastes. We must also comply with various health and safety regulations in the United States and abroad in connection with our operations. Failure to comply with any of these laws could result in civil and criminal, monetary and non-monetary penalties and damage to our reputation. In addition, we may incur costs related to remedial efforts or alleged environmental damage associated with past or current waste disposal practices. We cannot provide assurance that our costs of complying with current or future environmental protection and health and safety laws will not exceed our estimates. Excerpt: Forward-Looking Statement Safe Harbor (Page 3) . . .These risks also include the impact of governmental actions related thereto on Snap-on’s business, as well as uncertainties related to Snap-on’s capability to implement future strategies with respect to its existing businesses, its ability to refine its brand and franchise strategies, retain and attract franchisees, further enhance service and value to franchisees and thereby help improve their sales and profitability, introduce successful new products, successfully pursue, complete and integrate acquisitions, as well as its ability to withstand disruption arising from natural disasters, planned facility closures or other labor interruptions, the effects of external negative factors, including adverse developments in world financial markets, developments related to tariffs and other trade issues or disputes, weakness in certain areas of the global economy (including as a result of the United Kingdom’s exit from the European Union and the COVID-19 pandemic), and significant changes in the current competitive environment, inflation, interest rates and other monetary and market fluctuations, changes in tax rates, laws and regulations as well as uncertainty surrounding potential changes, and the impact of energy and raw material supply and pricing, including steel (as a result of U.S. tariffs imposed on certain steel imports or otherwise) and gasoline . . . We will continue to disclose the material effects of transition risks related to climate change, as appropriate, to reflect changes or anticipated changes in governmental policy and regulations and as relevant market trends develop and evolve. Management’s Discussion and Analysis of Financial Condition and Results of Operations (“MD&A”), page 27 We note that you list several future climate-related projects on your Sustainability Commitment webpage. Please revise your disclosure to identify any material past and/or future capital expenditures for climate-related projects. If material, please quantify these expenditures. The capital projects identified on our Sustainability Commitment webpage represent our commitment to addressing environmental concerns as an integral part of our operational and manufacturing processes. As a manufacturer, we are continually assessing our processes to identify areas of improvement and efficiency. In this process, we consider a wide range of factors – safety, labor utilization, material costs, energy costs, and the cost of capital, in addition to the environment. In describing the various activities on our sustainability webpage, we do not suggest that these projects were undertaken primarily, or exclusively, for the purpose of addressing climate change, nor does our inclusion of an activity on the webpage imply that the cost of the project is material for SEC reporting purposes. During the period covered by the Snap-on 10-K, we have not incurred, nor have we committed to incur, material capital expenditures primarily for climate-related projects. If, in the future, we undertake any material capital project with the primary purpose of addressing climate change, we will disclose appropriate detail about the project and the anticipated expenditures. 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; and •increased competition to develop innovative new products that result in lower emissions. We have not to date experienced material indirect consequences of climate-related regulation or, to the extent discernible as climate-related, business trends, including as a result of the items noted above. However, we address this topic generally in the Snap-on 10-K with the following disclosures: Risk Factors – Operational Risks (Page 15) Risks associated with the disruption of manufacturing operations could adversely affect our profitability or competitive position. We manufacture a significant portion of the products we sell. Any prolonged disruption in the operations of our existing manufacturing facilities, whether due to technical or labor difficulties, facility consolidation or closure actions, lack of raw material or component availability, destruction of or damage to any facility (as a result of natural disasters, weather events, use and storage of hazardous materials, acts of war, sabotage, or terrorism, civil unrest or other events), or other reasons, including outbreaks of infectious diseases, such as the current COVID-19 pandemic, could have a material adverse effect on our business, financial condition, results of operations and cash flows. Price fluctuations and shortages of raw materials, components, certain finished goods inventory and energy sources could adversely affect the ability to obtain needed materials or products and could adversely affect our results of operations. The principal raw material used in the manufacture of our products is steel, which we purchase in competitive, price-sensitive markets. To meet Snap-on’s high quality standards, our steel needs range from specialized alloys, which are available only from a limited group of approved suppliers, to common alloys, which are available from multiple suppliers. Some of these materials have been, and in the future may be, in short supply, particularly in the event of mill shutdowns or production cut backs. In addition, outbreaks of infectious diseases, weather events or other circumstances beyond our control could also impact the availability of raw materials. As some steel alloys require specialized manufacturing procedures, we could experience inventory shortages if we were required to use an alternative manufacturer on short notice. These and other raw materials, components and certain finished goods inventory can exhibit price and demand cyclicality, including as a result of tariffs and other trade protection measures. Associated unexpected price increases could result in an erosion of product margins or require Snap-on to increase prices to customers to maintain margins. We use various energy sources to transport, produce and distribute products, and some of our products have components that are petroleum based. Petroleum and energy prices have periodically increased significantly over short periods of time; future volatility and changes may be caused by market fluctuations, supply and demand, currency fluctuations, production and transportation disruptions, world events and changes in governmental programs. Energy price increases raise both our operating costs and the costs of our materials, and we may not be able to increase our prices enough to offset these costs. Higher prices also may reduce the level of future customer orders and our profitability. Snap-on is subject to various federal, state and local government requirements regulating the discharge of materials into the environment or otherwise relating to the protection of the environment. Snap-on’s policy is to comply with these requirements and the company believes that, as a general matter, its policies, practices and procedures are properly designed to prevent unreasonable risk of environmental damage, and of resulting financial liability, in connection with its business. Some risk of environmental damage is, however, inherent in some of Snap-on’s operations and products, as it is with other companies engaged in similar businesses. Snap-on is and has been engaged in the handling, manufacture, use and disposal of many substances classified as hazardous or toxic by one or more regulatory agencies. Snap-on believes that, as a general matter, its handling, manufacture, use and disposal of these substances are in accordance with environmental laws and regulations. It is possible, however, that future knowledge or other developments, such as improved capability to detect substances in the environment or increasingly strict environmental laws and standards and enforcement policies, could bring into question the company’s handling, manufacture, use or disposal of these substances. Quantitative and Qualitative Disclosures About Market Risk, Commodity Risk (Page 52) Snap-on is a purchaser of certain commodities such as steel, natural gas and electricity. The company is also a purchaser of components and parts that are integrated into the company’s end products, as well as the purchaser of certain finished goods, all of which may contain various commodities including steel, aluminum, nickel, copper and others. Snap-on’s supply of raw materials and purchased components are generally and readily available from numerous suppliers. The principal raw material used in the manufacture of the company’s products is steel, which the company purchases in competitive, price-sensitive markets. To meet Snap-on’s high quality standards, the company’s steel needs range from specialized alloys, which are available only from a limited group of approved suppliers, to common alloys, which are available from multiple suppliers. Some of these materials have been, and in the future may be, in short supply, particularly in the event of mill shutdowns or production cut backs. As some steel alloys require specialized manufacturing procedures, Snap-on could experience inventory shortages if it were required to use an alternative manufacturer on short notice. Steel and other raw materials, components and certain finished goods inventory can exhibit price and demand cyclicality, including as a result of tariffs and other trade protection measures. Associated unexpected price increases could result in an erosion of product margins or require Snap-on to increase prices to customers to maintain margins. Snap-on believes its ability to sell product is also dependent on the changing vehicle repair requirements, the number of vehicles on the road, the general aging of vehicles and the number of miles driven. These factors affect the frequency, type and amount of service and repair performed on vehicles by technicians, and therefore affect the demand for the number of technicians, the prosperity of the technicians and, consequently, the demand technicians have for the company’s tools, other products and services, and the value technicians place on those products and services. The use of other methods of transportation, including more frequent use of public transportation, could result in a decrease in the use of privately operated vehicles. A decrease in the use of privately operated vehicles may lead to fewer repairs and less demand for the company’s products. To the extent that commodity prices increase and the company does not have firm pricing agreements with its suppliers, the company may experience margin declines to the extent that it is not able to increase the selling prices of its products. If, in the future, we determine that the indirect consequences of climate-related regulation or business trends are or may reasonably be expected to be material, we will discuss those matters in our MD&A, as appropriate. If material, discuss the significant physical effects of climate change on your operations and results. This disclosure may include the following: •severity of weather, such as floods, hurricanes, extreme fires, and water availability and quality; •quantification of material weather-related damages to your property or operations; and •any weather-related impacts on the cost or availability of insurance. Like most manufacturing businesses, our operations are subject to disruptions caused by natural disasters, including floods, storms, and fires. In recent years, we have experienced numerous significant weather events across our global footprint, but these events have not materially disrupted our business or materially affected our financial condition or results of operations. We recognize that climate change influences weather patterns and that some of our locations might be adversely affected by more frequent or different weather-related events from time to time in the future. These disruptions can be challenging, costly, and in some cases, may displace our workforce, suppliers, and/or customers. However, we believe, based on our past experiences, our breadth of products, our range of customers and our geographic diversity, that the impact of these events on our business tends to be short term. If, in the future, we determine that the physical effects of climate change have had, or are reasonably likely to have, a material impact on our operations or results, we will discuss those matters in our MD&A, or elsewhere in our Form 10-K, as appropriate.

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We note that you list several future climate-related projects on your Sustainability Commitment webpage. Please revise your disclosure to identify any material past and/or future capital expenditures for climate-related projects. If material, please quantify these expenditures.

See the reply above.

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; and • increased competition to develop innovative new products

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that result in lower emissions.

See the reply above.

If material, discuss the significant physical effects of climate change on your operations and results. This disclosure may include the following: • severity of weather, such as floods, hurricanes, extreme fires, and water availability and quality; • quantification of material weather-related damages to your property or operations; • any weather-related impacts on the cost or availability of insurance.

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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.

See the reply above.

Your response to prior comment 1 refers to general disclosure of environmental regulation and risks, and the various risks identified in your forward-looking statement. In light of your industry and business operations, please tell us about the specific transition risks related to climate change relevant to you (such as those noted in our prior comment) and explain how you considered providing disclosure.

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Please also explain how you determined the materiality of their effects on your business, financial condition, and results of operations.

1:

The company continually monitors transition risks related to climate change, including potential policy and regulatory changes, technology changes, market trends, stakeholder views and credit risks.

We understand the increasing focus on climate-related issues by investors and other constituencies, and we are paying close attention to stakeholders’ views in this area.

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Snap-on strives to implement environmentally sound policies designed to prevent, mitigate and reduce the impact on the environment or the communities in which we operate.

Determinations of materiality are undertaken by considering whether there is a substantial likelihood that the information, including transition and other risks, would have been viewed by the reasonable investor as having significantly altered the total mix of information made available. Snap-on assesses the materiality of transition risks related to climate change for reporting purposes by first undertaking a quantitative assessment of the potential impact of such risk. After considering the potential quantitative impact, the company then considers qualitative factors, including the potential effects on relationships with customers and suppliers, changes in customer behavior and the impact on these and other stakeholders.

We expect the pace of policy and regulatory changes, such as, for example, potential regulations related to emissions standards, to be measured and deliberate as governments consider the impact of proposed climate change laws and regulations on their constituencies, markets and economies. We anticipate that the pace by which these regulations are implemented will provide companies with the ability to adapt to such changes over time. The company is closely following regulatory developments in this area.

Snap-on has historically benefited from changes in car and truck fleets – whether as a result of technological changes or market trends – because these changes drive the need for new tools, technologies and data to monitor, service and repair these new vehicles. The current period of transition from internal combustion engine technology to alternative or renewable energy technologies is yet another example of the kind of change that we believe presents our business with opportunities. In addition, we believe that any perceived risks caused by changes in technology related to climate change will be outweighed by the opportunities these changes present and we do not expect that such changes will outpace our ability to respond.

Consistent with past experience, and as is currently being observed, we anticipate that technological changes and market trends in the transportation industry, whether relating to the adoption of alternative fuels, responding to climate change concerns or otherwise, will evolve and mature over time for a number of reasons. First, the established vehicle parc in the U.S. and globally is considerable, and individuals, as well as businesses and public entities, have invested significant capital in their existing cars, trucks and transportation devices and would face significant costs to replace their vehicles with alternative energy platforms.

Second, while great attention and energy is currently being focused on electric and hybrid vehicles, the rate of adoption of these technologies as a percentage of the entire established vehicle parc remains relatively low. Even assuming a significant rate of adoption of any one, or any combination of, alternative technology, it is anticipated to be a number of years before any alternative technology would be expected to displace a material percentage of the established vehicle parc.

Third, we believe that advances in the global supply chain will be needed to keep pace with the manufacturing and repair demands that would be required in order to see one or all of the current alternative energies outpace current vehicle technology. In addition, we believe that the demand for rare earth minerals used in current battery powered vehicles will temper electric vehicle growth until further design or innovation can overcome resource and budget constraints.

Fourth, the current electrical grid infrastructure needs considerable investment, and significant additional infrastructure investment will be needed, to address the increased demand for electricity to recharge an expanding electric vehicle parc. Lastly, other clean energy alternatives are continually being pursued and it is unclear what technology will ultimately be adopted or whether numerous alternatives will become acceptable options. In addition, certain alternatives, such as hydrogen, may pose other logistical and safety concerns that will require innovation, investment, maintenance protocols and time to overcome.

The company believes that one of the more significant ways in which transition risks are expected to manifest themselves is through price and availability of energy and raw materials to produce, deliver and fulfill customer orders. Our total utility costs (electricity, gas and water) for fiscal 2020 represented less than 1% of total costs, including cost of goods sold, operating expenses and financial services expenses. While these costs were slightly lower than prior years as a result of the impact of the COVID-19 pandemic, they have been less than 1% of total costs for the past several years. The company has made incremental changes to improve our energy efficiency over the years through the use of energy efficient lighting, heating and cooling systems, and other improvements as we upgrade our facilities, machinery and equipment. The company has not experienced significant changes in utility costs, whether as a result of climate change or otherwise to this point. In addition, while transition risks linked to climate change could impact the company’s supply of raw materials and purchased components, such materials and components are generally and readily available from numerous suppliers. The company actively manages its supply needs and continuously works to expand its supplier base to ensure the availability of raw materials and components. We believe that significant increases in the cost of utilities, raw materials and other components would need to occur for an extended period of time, and outpace the benefits from our Rapid Continuous Improvement (“RCI”) and other initiatives, before such costs would become material to the company. See also our response to Comment 4.

Snap-on has not seen significant credit risks as a direct result of climate change. The industries we serve will likely require greater inflows of capital as the world transitions to renewable energy sources. In addition, we expect that the financial health of vehicle technicians will continue to outpace wage growth of the general workforce population, as we anticipate a higher demand for skilled technicians to service growing renewable energy fleets and the new technologies they will incorporate.

Transition risks related to climate change have not had a meaningful impact on Snap-on to this point. However, we continue to closely monitor these risks and will update our future disclosures in the event those transition risks are identified, quantified and determined to be material to our businesses.

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We note from your response to prior comment 2 that you have not incurred or committed to incur material capital expenditures primarily for climate-related projects. Provide us with support for this statement, including quantitative information.

2:

While we have incurred costs to improve our energy efficiency through, for example, the use of energy efficient lighting, heating and cooling systems, and other improvements as we upgrade our facilities, machinery and equipment, we have not incurred material capital expenditures primarily for climate-related projects.

Our capital expenditures in fiscal 2020 were $65.6 million. The two largest single expenditures were $9.2 million (0.1% of net assets) and $2.1 million (less than 0.1% of total assets). In fiscal 2019, our capital expenditures were $99.4 million.

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The two largest single expenditures were $12.5 million (0.2% of total assets and $4.0 million (less than 0.1% of total assets). None of these four identified capital expenditures were associated with climate change-related matters. The other capital expenditures in fiscal 2020 and 2019 related to the purchases or expansions of facilities, numerous machine upgrades and other capacity expansion projects across our various businesses that were primarily intended to drive operational efficiency.

The company is monitoring climate-related developments and to the extent we allocate material capital expenditures that we believe are primarily for climate-related purposes, we will disclose appropriate information about such projects in our future filings with the Commission.

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Your response to prior comment 3 appears to be conclusory in nature without providing sufficient detail regarding the indirect consequences of climate-related regulation or business trends, including the specific items noted in our comment. Please describe the indirect consequences of climate change you considered in your response and explain how you concluded they were not material.

3:

In our response to comment 1 above, we highlighted several business trends that we considered, as well as described our method of assessing the materiality of transition risks related to climate change. We also described why energy prices do not currently pose a material risk to our company beyond the risks we have outlined in our risk factors and other filings with the Commission.

We actively monitor developments in the transportation industry as well as issues facing critical industries, and we discuss changes in the regulatory and competitive environment at least quarterly with the

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management teams of each of our operating segments. To this point, climate-related rules and regulations in the U.S. and globally are still developing and have not caused noticeable changes in business trends affecting our company.

While it is expected that the use of internal combustion engine vehicles will eventually decline over time and be replaced by renewable energy vehicles, we believe the size of the worldwide vehicle parc is likely to continue to increase. The renewable energy vehicle market is growing (though it still represents an extremely small portion of the total vehicle market) and includes many new competitors beyond existing auto and truck manufacturers. These manufacturers and the new technologies they are developing will require service, calibration and a capable workforce for service and repair needs. A core tenant of Snap-on is innovation. We are a leading global innovator in the vehicle repair and maintenance space, and we believe that changes in vehicle technology present our businesses with significant opportunities for growth.

Snap-on will continue to provide solutions in the alternative energy arena, as well as solutions to improve efficiency in conventional energy usage. This includes, for example, Snap-on’s design and supply of solutions for use in alternative energy industries such as wind turbines, and various products that can help improve automobile efficiency, including engine diagnostics and precision tire alignment. Snap-on also produces insulated tools that can be used in servicing electric vehicles and precision alignment tools that will help maintain the vehicle parc as it moves towards a long-term future of autonomous driving.

If material changes in business trends are identified in the future, we will disclose those changes as appropriate in our filings with the Commission.

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Among the disclosures cited in your response to prior comment 3 is language which describes price fluctuations and supply shortages of steel and petroleum-based energy sources, as well as changing vehicle requirements, but does not appear to specifically relate these types of issues to climate change.

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Please tell us what consideration you gave to identifying and analyzing these changes as indirect consequences of climate-related regulation or business trends.

4:

Snap-on experiences raw material and component price fluctuations and continuously works to expand its supplier base to ensure availability of raw materials and to purchase products at reasonable costs. While price fluctuations do occur from time to time, including due to the ongoing COVID-19 environment, management has adjusted to these challenges through its RCI efforts, which include continuously striving to improve efficiencies and reduce waste in order to minimize the impact of cost increases.

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The financial impact on our company related to supply shortages and/or cost increases is expected to be similar whether the manifestation of the risk is the result of the direct or indirect impact of climate change or from other factors. To date, we have not observed any noticeable supply shortages or price increases directly or indirectly resulting from climate change factors. However, if such factors materially impact future costs, we will provide appropriate disclosure.

To the extent that direct or indirect climate-change-related risk, including, for example, due to physical risks related to climate change such as a weather event, drives measurable, material impacts on the company, we will provide appropriate disclosure in future filings with the Commission.

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Your response to prior comment 4 recognizes that climate change influences weather patterns, indicates that you have experienced numerous significant weather events, and recognizes disruptions can be costly. Tell us how you considered providing disclosure discussing the significant physical effects of climate change as it relates to its influence on weather patterns, such as floods, hurricanes, extreme fires, and

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water availability and quality. In addition, please describe the weather events you have experienced and the impact on your business, financial condition, and results of operations. To the extent you quantified amounts, such as weather-related damages and/or the cost of insurance, please provide these and explain how you analyzed materiality.

5:

Snap-on and its mobile franchisee van channel on occasion have been impacted by hurricanes and related flooding, as well as by wildfires, which we identified accordingly in the disclosures and cautionary statements included in our prior filings with the Commission. For example, in the risk factors to our 2006 Form 10-K, we included the following language:

•“Franchisees have historically experienced business interruptions due to adverse weather conditions or other extraordinary events, such as hurricanes in the southern United States and wildfires in California.

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To the extent our franchisees experience future similar events, our operating results may be adversely impacted.”

In the third quarter of 2017, we modified our cautionary statement to include language related to then-recent hurricanes as follows:

•“These risks also include…disruption arising from natural disasters (such as the recent hurricanes in the southern United States and the Caribbean)….”

In both cases noted above, there was disruption to our franchisees and their customer base, but the measurable impact in both instances was immaterial, and business recovered to pre-disaster levels shortly thereafter. Snap-on incurred minimal losses for loan write-offs and other storm or wildfire-related impacts. In addition, Snap-on’s sales in periods following these events may have benefited as businesses impacted by these events recovered and replaced tools and equipment damaged in the flooding and wildfires.

We did not experience any weather or fire-related insurance claims in fiscal 2020 or 2019. In 2018, we had one claim for $0.3 million related to hail and wind damage. Our worldwide cost of property insurance was less than 0.1% of total costs for each of the reported periods in the 2020 Form 10-K.

In addition, we have disclosed the impact of weather events among the potential risks to our operations in our risk factors included on pages 15 and 21 of the 2020 Form 10-K. Please see the highlighted references below:

•Risks associated with the disruption of manufacturing operations could adversely affect our profitability or competitive position.

We manufacture a significant portion of the products we sell. Any prolonged disruption in the operations of our existing manufacturing facilities, whether due to technical or labor difficulties, facility consolidation or closure actions, lack of raw material or component availability, destruction of or damage to any facility (as a result of natural disasters, weather events, use and storage of hazardous materials, acts of war, sabotage, or terrorism, civil unrest or other events), or other reasons, including outbreaks of infectious diseases, such as the current COVID-19 pandemic, could have a material adverse effect on our business, financial condition, results of operations and cash flows.

•Price fluctuations and shortages of raw materials, components, certain finished goods inventory and energy sources could adversely affect the ability to obtain needed materials or products and could adversely affect our results of operations.

The principal raw material used in the manufacture of our products is steel, which we purchase in competitive, price-sensitive markets. To meet Snap-on’s high quality standards, our steel needs range from specialized alloys, which are available only from a limited group of approved suppliers, to common alloys, which are available from multiple suppliers. Some of these materials have been, and in the future may be, in short supply, particularly in the event of mill shutdowns or production cut backs. In addition, outbreaks of infectious diseases, weather events or other circumstances beyond our control could also impact the availability of raw materials. As some steel alloys require specialized manufacturing procedures, we could experience inventory shortages if we were required to use an alternative manufacturer on short notice. These and other raw materials, components and certain finished goods inventory can exhibit price and demand cyclicality, including as a result of tariffs and other trade protection measures. Associated unexpected price increases could result in an erosion of product margins or require Snap-on to increase prices to customers to maintain margins.

•Economic conditions and world events could affect our operating results.

In addition to the specific risks above, we, our franchisees and our customers, may be adversely affected by changing economic conditions, including conditions that may particularly impact specific regions. These conditions may result in reduced consumer and investor confidence, instability in the credit and financial markets, volatile corporate profits, and reduced business and consumer spending. We, our franchisees and our customers, and the economy as a whole, also may be affected by future world or local events outside our control, such as tariffs and other trade protection measures put in place by the United States or other countries, acts of terrorism, developments in the war on terrorism, civil unrest, conflicts in international situations, weather events and natural disasters, outbreaks of infectious diseases such as the ongoing COVID-19 pandemic, as well as government-related developments or issues, including changes in tax laws and regulations. These factors may affect our results of operations by reducing our sales, margins and/or net earnings as a result of a slowdown in customer orders or order cancellations, impact the availability and/or pricing of raw materials and/or the supply chain, and could potentially lead to future impairment of goodwill or other intangible assets. In addition, political, social turmoil, international conflicts and terrorist acts may put pressure on global economic conditions. Unstable political, social and economic conditions may make it difficult for our franchisees, customers, suppliers and us to accurately forecast and plan future business activities. If such conditions persist, our business, financial condition, results of operations and cash flows could be negatively affected.

If a future weather event has a material impact on our operations or franchisee sales network, or if the physical risks of climate change are determined to be material, we will provide appropriate disclosure in our filings with the Commission.

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