New SEC Search Tool Finds Inadequate Human and Workers’ Rights Disclosure in Financial Filings

Standouts discuss risks and opportunities, but few report financial implications
May 31, 2018 12:00 PM ET
Campaign: Human Rights

May 31, 2018 /3BL Media/ - Ceres and CookESG Research released a new tool for identifying corporate disclosure of human and workers’ rights risks and opportunities in annual financial filings. The tool covers more than  5,000 U.S. and foreign companies’ filings (10-K, 20-F and 40-F) to the U.S. Securities and Exchange Commission. The SEC search tool also expands Ceres’ work to address investors’ concerns about improving the disclosure of decision-useful sustainability information in mandatory filings.

“In an era when companies face growing scrutiny for their human and workers’ rights policies and practices, and greater responsibilities for helping to address global sustainability threats, improving disclosure of the associated financial risks and opportunities to investors is an imperative,” said Jim Coburn, senior manager of disclosure at Ceres.  

On critical issues of human rights and workers’ rights, the tool shows examples of good practice disclosure. But even these examples fail to detail the financial implications of these risks and opportunities.  Given the financial risks human rights and workers’ rights issues pose in many industries, investors are increasingly taking stock of opportunities for improved disclosures so they can better integrate human and workers’ rights risks into their corporate engagements and investment decision-making.

The search tool captures information--where it is disclosed--about internationally recognized human rights such as freedom of association, the right to collective bargaining, non-discrimination, and the elimination of forced and child labor. The tool categorizes disclosure as four types, providing investors information on the following: human rights policies and practices, equal employment and anti-discrimination, workers’ rights and workplace practices, and social license to operate.

Using the tool to review 2015-2018 disclosures, Ceres and CookESG Research found that S&P 500 companies disclosed more information about workers’ rights and workplace practices than about human rights, equal employment, and anti-discrimination policies. Foreign companies generally disclosed more information than their U.S. competitors.  Overall, however, companies failed to detail the financial implications of human and workers’ rights-related risks and opportunities.

For industry sectors with at least 10 companies analyzed, chemical, medical equipment manufacturers and oil and gas companies disclosed the most information about human rights. However, business services, electronics and insurance services companies disclosed the least amount of information.

“Increasingly, investors are recognizing that human rights, worker treatment and community relations intersect with environmental and governance issues and are material sources of business strength and business risk,” said Jackie Cook, head of CookESG Research. “Discussion of their impacts belongs in annual financial reporting to shareholders.”

Examples of corporate disclosures found by the tool include:

  • Human rights due diligence – Communications and information technology company Nokia --“[W]e have identified the potential misuse of the products and technology we provide, as the most salient human rights risk in our operations...In 2017, to increase transparency, we became the first telecoms vendor to publish real human rights due diligence cases to increase the dialogue and understanding of the issues vendors can face. We run human rights due diligence processes as part of our global sales process, to further mitigate the potential risks of product misuse.”
  • Supply chain human rights – Beverages bottler and consumer goods company Coca-Cola European Partners -- “We are also working to embed sustainability, ethics and human rights within our supply chain…CCEP's Human Rights Policy is guided by international human rights principles encompassed in the Universal Declaration of Human Rights, the International Labour Organisation's Declaration on Fundamental Principles and Rights at Work, the United Nations Global Compact and the United Nations Guiding Principles on Business and Human Rights. In 2017, we published our first response to the UK Modern Slavery Act, and will publish further updates on our progress on embedding human rights and sustainability in our supply chain in our 2017 Stakeholder Progress Report.”
  • Gender diversity – Oil and gas exploration and production company Equinor (formerly Statoil) -- “During 2017, we continued to analyse the diversity of our pipeline, at all levels and in all locations, to ensure continued improvement in our representation. In 2017, the overall percentage of women in the company was 30 percent. The percentage of women in the board of directors is 40 percent...The percentage of women in leadership positions was 28 percent in 2017.”
  • Board responsibility for sustainability issues – Intercontinental Hotels discussed the role of its Corporate Responsibility Committee, including, “Monitoring delivery of the Group’s Responsible Business targets for 2013-2017, and establishing new targets for 2018–2020 [and] Reviewing Environmental, Social, Community and Human Rights issues including the Group’s Modern Slavery Statement and the Group’s approach to responsible procurement.”

The search tool, introduced in 2014 by Ceres and CookESG Research, also provides users the ability to search for disclosures on these sustainability issues: climate change, water risk, carbon asset risk, and hydraulic fracturing.


Ceres is a sustainability nonprofit organization working with the most influential investors and companies to build leadership and drive solutions throughout the economy. For more information, visit and follow @CeresNews.