Oct. 22, 2019
Dear Commissioner Countryman, Thank you for taking on the task of modernizing Reg S-K disclosures on human capital. As a long-term investor in public capital markets at Equinox Partners ($2bn AUM) and Radiant Value Partners, I have struggled to discern the risks and oppotunities posed to potential investments from human capital. While some companies do qualify aspects along this dimension, rarely do I find these verbal descriptions decision useful, as they are not comparable, complete, or relevant. Because of the SEC’s proposal is principles-based, I would strongly encourage or require companies to use an investor-focused disclosure framework developed through due process, such as the SASB framework. I do not necessarily require more disclosure, but material company-specific aspects based on an industry-driven, stakeholder-verified framework. Thank you kindly. I am happy to follow-up should you require any further clafications. Best regards, Isuru Seneviratne Radiant Value Management Tel: [redacted] 35-20 Leverich St #A609 | Jackson Heights, NY 11372 | radiantval.com Modernization of Regulation S-K Items 101, 103, and 105 Vanessa A. Countryman Secretary, Securities and Exchange Commission 100 F Street NE, Washington, DC 20549-1090. Dear Commissioner Countryman, Thank you for taking on the task of modernizing Reg S-K disclosures on human capital. As a long-term investor in public capital markets at Equinox Partners ($2bn AUM) and Radiant Value Partners, I have struggled to discern the risks and oppotunities posed to potential investments from human capital. While some companies do qualify aspects along this dimension, rarely do I find these verbal descriptions decision useful, as they are not comparable, complete, or relevant. Because of the SEC’s proposal is principles-based, I would strongly encourage or require companies to use an investor-focused disclosure framework developed through due process, such as the SASB framework. I do not necessarily require more disclosure, but material company-specific aspects based on an industry-driven, stakeholder-verified framework. Thank you kindly. I am happy to follow-up should you require any further clafications. Best regards, Isuru Seneviratne Radiant Value Management Tel: 646 462 9018 35-20 Leverich St #A609 | Jackson Heights, NY 11372 | radiantval.com NOTICE: This email and any attachments transmitted with it are confidential and intended solely for the use of the individual(s) or entity to whom they are addressed. Please notify the sender immediately by e-mail if you have received this e-mail by mistake and delete this e-mail and all copies of it from your system. If you are not the intended recipient you are notified that disclosing, copying, distributing or taking any action in reliance on the contents of this information is strictly prohibited. Sender does not intend to waive confidentiality or privilege.