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May-June 2023

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36 PalletCentral • May-June 2023 palletcentral.com footprint of a corporation (and its downstream vendors and partners) – understanding where materials are sourced, whose hands touch the materials, and the journey the materials or product take around the world until reaching the manufacturing or other worksite in the U.S. Key items will be use of child labor, mining, conflict minerals utilization, and practices that do negatively impact environmental sustainability (e.g., logging practices). e SEC proposal sets up a reporting framework that would require disclosure of specified information in annual reports and corporate stock registration statements by publicly traded companies. Some speculate that this could be the "new Sarbanes-Oxley" in terms of impact on risk- based internal audits for environment, safety and health, other organizational and regulatory areas that influence "ESG" disclosures to shareholders and potential investors. It is also likely to have whistle blower protections included, and those would be enforced by OSHA (which already enforces those protections in SEC rules, as well as those of the EPA, DOT and worker safety provisions). e proposed rule, which could be modified after consideration of comments received last year, contains the following provisions: • Requires registrants to provide certain climate- related info in registration statements and annual reports, including greenhouse gas emissions and other climate financial metrics; • Requires information about the SEC registrant's "climate-related risks" reasonably likely to have "material impact on its business, results of operations, or financial condition" disclosure rule with transparency; and • Requires publicly traded companies to conduct three levels of analysis on climate impact: (1) direct iStock/Boy Wirat

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