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


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Date Received
Date Sort descending Letter Type Commenter Name
Public Comment Allan Emkin, Founder and Managing Director, Pension Consulting Alliance, LLC
Public Comment Martin Whittaker, CEO, JUST Capital
Public Comment Kerrie Waring, Executive Director, and Joyce Haboucha, Co-Chair, Disclosure and Transparency Committee; International Corporate Governance Network
Public Comment Scott Connolly, Assistant Secretary, Australian Council of Trade Unions
Public Comment Dieter Waizenegger, Executive Director, CtW Investment Group
Public Comment Jeffrey P. Mahoney, General Counsel, Council of Institutional Investors
Public Comment Catherine Howarth, Chief Executive, ShareAction
Public Comment Ken Hall, General Secretary-Treasurer, International Brotherhood of Teamsters
Public Comment Stephen Davis, Ph.D., Associate Director and Senior Fellow, Harvard Law School Programs on Corporate Governance and Institutional Investors
Public Comment Denise L. Nappier, State Treasurer, State of Connecticut
Public Comment Gary Yee, Board Chair, British Columbia Municipal Pension Board of Trustees
Public Comment Heidi Soumerai, Managing Director, Director of ESG Investing, Walden Asset Management, Boston Trust & Investment Management Company
Public Comment Jon Lukomnik
Public Comment Public Citizen
Public Comment Richard A. Bennett, President & CEO, and Nell Minow, Vice Chair, ValueEdge Advisors LLC
Public Comment Heather Slavkin Corzo, Director, Corporations and Capital Markets, AFL-CIO
Public Comment Josh Zinner, Chief Executive Officer, Interfaith Center on Corporate Responsibility
Public Comment Larry Beeferman, Director, and Aaron Bernstein, Senior Research Associate; Pensions and Capital Stewardship Project, Labor and Worklife Program, Harvard Law School
Public Comment Stephen F. O'Byrne, President, Shareholder Value Advisors Inc.
Public Comment Michael W. Frerichs, State Treasurer of Illinois
Public Comment Stuart Woollard, Managing Partner, Organizational Maturity Services LLP
Public Comment Ronald B. McKinley, Chair, ISO TC/260
Public Comment Paul Kearns, Chair, Maturity Institute
Public Comment 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)

Last Reviewed or Updated: Dec. 18, 2025