ESG Disclosure Trends in SEC Filings

Many companies also highlighted their business continuity planning in disclosures in light of potential COVID-19-related disruptions.1 This disclosure was in line with recent SEC disclosure guidance in Topics No. 9 and 9A, which both emphasize the importance of disclosing material information regarding employee matters due to the pandemic, such as employees' transition to remote working arrangements, the modification of operations to comply with health and safety guidelines to protect employees, and constraints on human capital resources and productivity. Overall, 45 of the 50 companies surveyed (or 90%) included some form of HCM disclosure in their 2020 Form 10-K or annual meeting proxy statement, representing an 8% increase from 2019. [...]35 of the 2020 filings surveyed (or 70%) showed an increase in this type of disclosure from 2019. In July 2020, the NYC Comptroller, on behalf of three New York City Retirement Systems with over $200 billion in assets, sent a letter to the CEOs of 67 S&P 100 companies calling on them to adopt a policy to publicly disclose diversity data with a comprehensive breakdown by race, ethnicity, and gender in 10 employment categories, including senior management, and provide a written commitment to do so by August 30, 2020 or face the risk of a proposal on this topic submitted to a shareholder vote.7 2.Environmental Matters Twenty-nine of the 2020 filings (or 29%) increased their environmental disclosure from 2019. [The company] has over 86 renewable energy projects, including 26 utility-scale wind and solar farms and 60 solar rooftops installed on fulfillment centers and sort centers around the globe;... Since 2008... [we] saved more than 810,000 tons of packaging material and eliminated the use of 1.4 billion shipping boxes."