How to Handle “Human Capital Management” Disclosure
June 7, 2021 •
Our guests – Davis Polk’s Ning Chiu, Prudential’s Peggy Foran, Shearman & Sterling’s Gillian Emmett Moldowan and Cooley’s Amy Wood – delve into “human capital management” disclosures, including:
- What is now required by the SEC?
- What types of disclosures are investors looking for? Which investors are leading the charge for human capital disclosure?
- Do the proxy advisors have a position on human capital disclosure?
- To begin to craft this type of disclosure for the first time, what questions should you be asking to get a strategy together?
- What are the frameworks, the standards, out there that folks can look at to get ideas?
- A brief look at some of the disclosures out there so far since the SEC adopted it’s new regulation
- Where within the proxy should this disclosure be located?
- Who should be on the disclosure team for this?
- Should your independent auditors be hired to audit this type of disclosure?
- Should interested investors – your larger shareholders – be involved in reviewing a draft of the disclosure? What liability might you have for this disclosure?
- Where might this type of disclosure be made outside of SEC filings?
- What about board oversight? Where should that lie? Should committee charters be updated?