Subject: File No. S7-41-10
From: Teresa Fogelberg
Affiliation: Deputy Chief Executive, Global Reporting Initiative

March 2, 2011

The Global Reporting Initiative (GRI) follows with interest the Securities and Exchange Commissions proposed specialized disclosure of mine safety information.

In this context, the necessity for comparable data has been emphasized. The Global Reporting Initiative provides organizations and companies with the worlds most widely used system for sustainability reporting, as a free public good. A multi-stakeholder network, GRI has developed its Sustainability Reporting Framework and other services to help organizations report on how sustainable they are, and manage the transition to sustainable practices.

Sustainability reporting the practice of measuring and disclosing sustainability performance in a systematized way, like financial reporting - enables organizations to measure and understand their impacts on sustainability factors (the environment, the economy, society, labor practices, human rights, and products).

GRI has developed specific guidance for the mining and metals sector ensuring that sustainability reports by mining and metals companies effectively cover the sectors key issues. http://www.globalreporting.org/ReportingFramework/SectorSupplements/MiningAndMetals

GRI would be pleased to discuss any questions the Commission may have. For further information please contact Teresa Fogelberg, GRI Deputy Chief Executive (Fogelberg@globalreporting.org ) or Isabella Pagotto, Manager Government Relations and International Organizations (pagotto@globalreporting.org).