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Keeping you in-the-know on environmental, social and governance developments

Over at, John Jenkins blogged about the first year of the SEC’s human capital management disclosures. He takes a look at a memo on the matter from the law firm Gibson Dunn that analyzes the inaugural filings.

The firm surveyed 10-K filings from 451 members of the S&P 500, and found that disclosure practices varied pretty widely, “with no uniformity in their depth and breadth.” That makes disclosures difficult to compare, which is one reason why more prescriptive disclosure requirements are likely on the way.

In addition to discussing the types of disclosures that companies made, the memo also looks at disclosure practices within specific industries, including finance, tech, manufacturing, travel, retail and others. It also looks at how companies formatted their disclosures, the comments the Staff provided, and makes some recommendations for actions companies should take going forward.

With all the recent attention on climate disclosures and the international sustainability standards duel between IFRS/ISSB and EFRAG/GRI, it might be easy to forget about this existing ESG disclosure mandate in the U.S. And don’t worry – John is looking out for regulatory changes he thinks are on the way.

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The Editor

Lawrence Heim has been practicing in the field of ESG management for almost 40 years. He began his career as a legal assistant in the Environmental Practice of Vinson & Elkins working for a partner who is nationally recognized and an adjunct professor of environmental law at the University of Texas Law School. He moved into technical environmental consulting with ENSR Consulting & Engineering at the height of environmental regulatory development, working across a range of disciplines. He was one… View Profile