Human Capital Management: Should Your Independent Auditor Get Involved?
There are a wide variety of issues & topics raised for you to consider during this 38-minute Vid-Guide about handling “human capital management” disclosure with Davis Polk’s Ning Chiu, Prudential’s Peggy Foran, Shearman & Sterling’s Gillian Emmett Moldowan and Cooley’s Amy Wood. Hot topics include what this disclosure might look like (we parse some recent 10-K disclosures; also see this FW Cook memo) – and the potential liability for the disclosures you do make.
At the 28:14 mark, Prudential’s Peggy Foran brought up a “food for thought” issue – whether your independent auditors should be hired to audit these non-financial measures. The auditors are trying to break into this business – and that might be pricey for you. It’s early in the game – and there are some practical issues involved, such as how would they go about auditing some measures which don’t lend themselves easily to an audit. It’s something you should bear in mind as you look beyond this proxy season as this topic matures.
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