On July 19, 2016, the International Corporate Accountability Roundtable (ICAR) submitted the following letter to the U.S. Securities and Exchange Commission (SEC) in response to the SEC's recent Concept Release relating to the Business and Financial Disclosures Required by Regulation S-K. Specifically, ICAR addressed the SEC's inquiry into the disclosure of non-financial information on public policy and sustainability matters, maintaining that human rights policies, processes, and impacts are material to investment interests and therefore should be reported by registrants.
The SEC's request for comment is a key opportunity for ICAR to continue to push for mandatory human rights disclosure. These comments draw heavily from the arguments presenting in ICAR's 2013 report, Knowing and Showing: Using U.S. Securities Laws to Compel Human Rights Disclosure.
The comments are structured in three parts: (1) An introductory letter laying out the main arguments regarding human rights as material; (2) ICAR’s Knowing and Showing report; and (3) specific responses to a number of questions from the SEC’s Concept Release.
For further information, please contact Cindy Woods, Legal and Policy Fellow, at firstname.lastname@example.org.