Subject: Comment re: Rulemaking Petition File No. 4-711
From: Ronald B. McKinley
Affiliation: Chair, ISO TC/260

July 21, 2017

I am writing as the Chair of the International Organization for Standardization (ISO) Technical Committee (TC) 260 – Human Resource Management to support SEC approval of the requirement for publically traded organizations to report their human capital metrics in the same way they are required to report their financial performance.

As you may know, TC 260 is currently working on the development of international ISO Standard “30414 – Guidelines - Human Capital Reporting for Internal and External Stakeholders.” The standard is now in the committee draft stage, which means that I anticipate that it will be published by the Fall of 2018. I urge the SEC to, when the standard is published, adopt it as the SEC’s approach to organizational reporting of human capital metrics.


Ronald B. McKinley, PhD, MBA, SPHR
Chair, ISO TC/260 – HR Management