“Preparing for Potential Updates to Human Capital Management & Board Diversity Disclosure Requirements” from Kirkland & Ellis suggests companies start preparing now for the likely forthcoming SEC disclosure rules on human capital management and board diversity. The sound advice includes: (i) evaluating and updating current disclosures for upcoming filings by reviewing peer and leading disclosure practices, updating disclosures, and identifying appropriate metrics for data-gathering that will support new disclosure requirements; (ii) implementing/enhancing robust controls to ensure data quality and consistency across the company’s disclosures; and (iii) evaluating, and developing or strengthening, policies and programs, including governance structures, to promote enhanced oversight and performance.
The firm also suggests companies determine their policy positions and consider responding to the rule proposals once they are released, either independently or by participating in industry association comment letters. The Society will be commenting on these rule proposals and other anticipated SEC disclosure proposals under the leadership of its Securities Law and Sustainability Practices Committees.
The Society has a plethora of benchmarking data on human capital management and board diversity disclosures on our Human Capital/Workforce Management and Board Diversity pages, as well as our Annual Meeting/Proxy Statement page >>Samples/Templates.
This post first appeared in the weekly Society Alert!