Human Capital Management Disclosure

Resolution Text

WHEREAS: Human capital management disclosures are garnering attention in Congress1 and the SEC;2

The retail sector’s low-average wages, which help Advance maintain low product prices, may increase labor-related risks. Companies can face decreases in market share and revenue from negative consumer sentiment in the event of public disagreement between companies and workers;

The Sustainability Accounting Standards Board (SASB) has established sector-specific standards to assist companies in disclosing financially material, decision-useful sustainability information to investors. The standards identify a minimum set of sustainability issues most likely to impact operating performance or financial condition of the typical company in an industry. Businesses use SASB standards to better identify, manage, and communicate to investors sustainability information that is comparable, consistent, and financially material, thereby enabling better investment and voting decisions;

The SASB standards are recognized as financially material by mainstream investors. The SASB Investor Advisory Group, 48 global asset owners and managers “[b]elieve SASB’s approach--which is industry-specific and materiality-focused--will help provide investors with relevant and decision-useful information.”3 Members of the SASB Investor Advisory Group and SASB Alliance comprise seven of the ten largest worldwide money managers4 as well as pension funds of six states;5

SASB Labor Practices standards encompass average hourly wage and percentage of in-store employees earning minimum wage; voluntary and involuntary turnover rate for in-store employees; and total amount of monetary losses as a result of legal proceedings associated with labor law violations;

Yet, Advance does not disclose this financially material information. Its absence challenges investors’ ability to comprehensively evaluate our company’s management of sustainability risks and opportunities;

THEREFORE, BE IT RESOLVED: Shareholders request that the Board of Directors issue a report to shareholders describing the company’s policies, performance, and improvement targets related to material human capital risks and opportunities by 180 days after the 2020 Annual Meeting, at reasonable expense and excluding confidential information, including at a minimum reporting on average hourly wage and percentage of in-store employees earning minimum wage; voluntary and involuntary turnover rate for in-store employees; and total amount of monetary losses as a result of legal proceedings associated with labor law violations.

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1 Dana Wilkie, “Workplace May Be New Battleground for 2019-20 Congress,” November 7, 2018. Available at https://www.shrm.org/hr-today/news/hr-news/pages/2018-mid-term-election-workplace-legislation.aspx
2 Securities And Exchange Commission 17 CFR 229, 239, and 240 [Release Nos. 33-10668; 34-86614; File No. S7-11-19] RIN 3235-AL78. Modernization of Regulation S-K Items 101, 103, and 105. Available at https://www.sec.gov/rules/proposed/2019/33-10668.pdf
3 Support from Investors. https://www.sasb.org/investor-use/supporters/
4 Pensions & Investments “The Largest Money Managers,” May 27, 2019. At 25. https://www.pionline.com/assets/docs/CO119854528.PDF
5 SASB Alliance Organizational Members. https://www.sasb.org/alliance-membership/organizational-members/

Lead Filer

Andrew Behar
As You Sow