Subject: Comment to File Number 4-730
From: Martha Viehmann
Affiliation:

Oct. 18, 2018

There should be a  U.S. Securities and Exchange Commission requirement that corporate managers must be honest with their shareholders about what they are doing, and what their plans are.  But, as both a stockholder AND an employee of many large corporations over my lifetime, I know that all of their corporate effort has been spent in covering up, rather than in reporting, high level strategic decisions. This is WRONG and should be stopped by bringing real pressure and consequences to bear on upper management. 

Shareholders have a right to know if executives are buying off politicians or the media in an effort to hide pollution, environmental damage or to slow progress on addressing climate change. They also have a right to know whether the company is moving profits abroad to avoid paying taxes in the U.S.,  or if their products have hidden defects that harm the public or employees.  Shareholders should know if executives are funding racist, dark money, or politically manipulative activities with corporate monies. But even most employees cannot find out this information because it is hidden by upper management to protect their own high salaries. If someone is going to make $50million + a year, they should bear a responsibility for their management decisions and company actions commensurate with that pay, and that should include responsibility for data reporting ethics. 

The SEC should require public companies to disclose to their shareholders and the public the environmental, social, and governance (ESG) risks that the company faces. Management should be held responsible for failures. 

Thank you for considering my comment.

Virginia Madsen