Comments on Rulemaking petition to require issuers to disclose information about their human capital management policies, practices and performance

[File No. 4-711]

Submitted Comments

May 16, 2024 17 Communications, 1worker1vote, Align Impact, Amalgamated Bank, American Sustainable Business Network, Americans for Financial Reform Education Fund, Aspen Institute Economic Opportunities Program, B Lab US & Canada, B Local Wisconsin, BlueMark, The B Team, California Wellness Foundation, Change Finance, Chicory Wealth, Coalition for Inclusive Capitalism, Community Capital Advisors, Community Development Venture Capital Alliance (CDVCA), Confluence Philanthropy, Disability:IN, Evolution Marketing, Florida For Good, For the Long Term, Global Steering Group for Impact Investment, HCM Impact, HCMoneyball, Human Capital Management Institute, Impact Capital Managers, Impact Investing Institute, UK, Inspiring Capital, Intentional Endowments Network, Interfaith Center on Corporate Responsibility, JUST Capital, Kresge Foundation, Legacy Vacation Resorts, McKnight Foundation, National Community Investment Fund, Nia Impact Capital, Oxfam America, Pacific Community Ventures, PolicyLink, Predistribution Initiative, Public Citizen, Rights CoLab Salt Palm Development, Social Finance, Sorenson Impact Foundation, Soros Economic Development Fund, Surdna Foundation, Sustainable Development Investment Finance Partnership Toniic Institute, U.S. Impact Investing Alliance, Westfuller, Whistle Stop Capital WORC (Workforce & Organizational Research Center), and Workforce Disclosure Initiative, ShareAction
May 3, 2024 The Human Capital Management Coalition
Nov. 21, 2023 Thomas P. DiNapoli, New York State Comptroller
Aug. 29, 2023 Elizabeth H. Shuler, President, ALF-CIO
Oct. 2, 2022 James McRitchie, Shareholder Advocate/Publisher, Corporate Governance
Jul. 20, 2022 Ali-Reza Vahabzadeh, Executive Vice President Head of Membership, Chief of Staff & ESG Policy Co-Lead, American Sustainable Business Network
Mar. 16, 2022 Thomas P. DiNapoli, New York State Comptroller, et al.
Jan. 19, 2022 Elizabeth H. Shuler, President, et al., AFL-CIO
Jan. 11, 2022 Peter Haslag, Berk A. Sensoy, and Joshua T. White
Jan. 11, 2022 Kyle Bragg, President, SEIU
Dec. 8, 2021 Amy D. Augustine, Director, ESG Investing, Boston Trust Walden, et al.
Nov. 22, 2021 Dana Wise, Director of Corporate Engagement, Unite Here
Nov. 12, 2021 Robert Ludke, Senior Fellow, The Harkin Institute for Public Policy & Citizen Engagement
Oct. 26, 2021 Dieter Waizenegger, Executive Director, SOC Investment Group
Oct. 21, 2021 Henry E. M. Beck, Maine State Treasurer, et al.
Sep. 10, 2021 Dan Mauer, Director of Government Affairs, Communications Workers of America
Sep. 3, 2021 Ken Hall, General Secretary-Treasurer, International Brotherhood of Teamsters
Sep. 1, 2021 D. Taylor, International President, UNITE HERE
Oct. 22, 2019 Jonathan Grabel, Chief Investment Officer, Los Angeles County Employees Retirement Association
Apr. 29, 2019 Lee S. Webster, Founder, 1st Chair & 3rd Secretary, ISO TC 260 Human Resource Management
Feb. 1, 2019 Eleanor Bloxham, Founder and CEO, The Value Alliance and Corporate Governance Alliance
Jun. 15, 2018 Kathy Seabrook, Chairperson, Center for Safety and Health Sustainability
Apr. 25, 2018 Lawler Kang, Chief Executive Officer, League of Allies
Apr. 6, 2018 David Vance, Executive Director, Center for Talent Reporting
Jan. 9, 2018 Lee S. Webster, Healthcare Management Institute (HMI), University of Texas Medical Branch
Dec. 15, 2017 David F. Larcker, James Irvin Miller Professor of Accounting, Stanford Graduate School of Business
Dec. 7, 2017 Charlotte Laurent-Ottomane, Executive Director, Thirty Percent Coalition
Nov. 29, 2017 Mark C. Ubelhart
Nov. 20, 2017 Louise Davidson, CEO, Australian Council of Superannuation Investors
Oct. 31, 2017 Maureen O'Brien, Vice President, Director of Corporate Governance, Segal Marco Advisors
Oct. 23, 2017 Allan Emkin, Founder and Managing Director, Pension Consulting Alliance, LLC
Oct. 19, 2017 Martin Whittaker, CEO, JUST Capital
Oct. 17, 2017 Scott Connolly, Assistant Secretary, Australian Council of Trade Unions
Oct. 17, 2017 Kerrie Waring, Executive Director, and Joyce Haboucha, Co-Chair, Disclosure and Transparency Committee; International Corporate Governance Network
Oct. 16, 2017 Dieter Waizenegger, Executive Director, CtW Investment Group
Oct. 10, 2017 Jeffrey P. Mahoney, General Counsel, Council of Institutional Investors
Oct. 6, 2017 Ken Hall, General Secretary-Treasurer, International Brotherhood of Teamsters
Oct. 6, 2017 Catherine Howarth, Chief Executive, ShareAction
Oct. 4, 2017 Stephen Davis, Ph.D., Associate Director and Senior Fellow, Harvard Law School Programs on Corporate Governance and Institutional Investors
Oct. 2, 2017 Denise L. Nappier, State Treasurer, State of Connecticut
Sep. 29, 2017 Gary Yee, Board Chair, British Columbia Municipal Pension Board of Trustees
Sep. 28, 2017 Heidi Soumerai, Managing Director, Director of ESG Investing, Walden Asset Management, Boston Trust & Investment Management Company
Sep. 27, 2017 Richard A. Bennett, President & CEO, and Nell Minow, Vice Chair, ValueEdge Advisors LLC
Sep. 27, 2017 Jon Lukomnik
Sep. 27, 2017 Public Citizen
Sep. 22, 2017 Heather Slavkin Corzo, Director, Corporations and Capital Markets, AFL-CIO
Sep. 22, 2017 Josh Zinner, Chief Executive Officer, Interfaith Center on Corporate Responsibility
Sep. 21, 2017 Larry Beeferman, Director, and Aaron Bernstein, Senior Research Associate; Pensions and Capital Stewardship Project, Labor and Worklife Program, Harvard Law School
Sep. 18, 2017 Stephen F. O'Byrne, President, Shareholder Value Advisors Inc.
Sep. 12, 2017 Michael W. Frerichs, State Treasurer of Illinois
Aug. 8, 2017 Stuart Woollard, Managing Partner, Organizational Maturity Services LLP
Jul. 21, 2017 Ronald B. McKinley, Chair, ISO TC/260
Jul. 20, 2017 Paul Kearns, Chair, Maturity Institute
Jul. 10, 2017 Anne Simpson, Investment Director, Sustainable Investments, California Public Employees Retirement System (CalPERS), and Anne Sheehan, Director of Corporate Governance, California State Teachers' Retirement System (CalSTRS)