This SEC Institute Blog post highlights a fiscal 2020 Form 10-K comment letter exchange between SEC staff and Cintas Corporation that addresses the consistency of the company’s Form 10-K climate risk disclosure with its CSR report; its cap-ex for climate-related initiatives; indirect consequences of climate-related regulation or business trends on the company’s operations; the physical effects of climate change on the company’s operations and results; and transition risks. Notably, not unlike other climate comment letters we have reported on, the concept of materiality permeates the company’s responses in supporting its disclosure approach. See Corp Fin’s initial comment letter , the company’s response, the Corp Fin’s follow-up letter, and the company’s response to the follow-up, which was followed by the standard review closure letter.
See last week’s report: “SEC Comment Letter: Climate Disclosure” and these recent reports: “SEC Climate Disclosure Comment Letters” and “Form 10-K Climate Disclosures: Early Filers.” Access additional resources on our Climate Risk & Disclosure page.
This post first appeared in the weekly Society Alert!