Harkin Institute Fellow Robert Ludke submitted a letter to the Securities and Exchange Commission (SEC) providing feedback on the organization’s rule making petition requiring issues to disclose information about their human capital management policies, practices, and performance. Ludke is working with the Institute to promote greater disability representation in businesses, particularly at the executive level. 

Interest in the intersection between investments in human capital and corporate performance has grown in recent years among and investors, policymakers, executives, and human resources experts. For a number of years, the Securities and Exchange Commission has been working to create a framework by which publicly traded companies can disclose efforts to attract, retain, and grow their human talent. In 2020, the SEC proposed an initial disclosure framework that is widely seen as a good starting point. However, it is widely recognized that more work needs to be done to ensure organizations are truly investing in their employees – and creating financial and societal value from those investments.

Ludke’s letter provides a number of concrete recommendations for how the SEC can improve upon its 2020 framework. These recommendations can help investors and policymakers better understand how companies are using a strategic approach to disability inclusion to drive both shareholder and stakeholder value, and to encourage companies to provide more robust and meaningful disclosures around their efforts to achieve competitive, integrated employment for persons with disabilities.Read Ludke’s letter here.

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