Letters and Statements

2017 SEC Rulemaking Petition Urging Stronger Human Capital Disclosure

Full Petition Text (July 2017)

Petition Summary

Comments Submitted to SEC on Rulemaking Petition

Other Comment Letters

Comment to the SEC Investor Advisory Committee Supporting Guidance on COVID-19 Disclosures (May 2020)

Comment to the SEC re: Human Capital Disclosure Changes to Rule S-K Items 101, 103, and 105 (October 2019)

Comments Submitted to SEC on Human Capital Disclosure Rulemaking

2019 Comment to the SEC Investor Advisory Committee Supporting Enhanced Human Capital Disclosure Recommendation (March 2019)