According to the Society, the metrics contemplated by the standard are not material to investors, nor are investors
requesting the information. In addition, the cost of publicly disclosing these metrics would be excessive. Gathering, aggregating, standardizing and certifying the data is time intensive
and costly.
Moreover, substantial explanation is required to provide the context necessary to understand the meaning of most metrics (e.g., engagement survey results), adding to already long corporate disclosures without substantially improving understanding of a company’s operations. Disclosure of metrics does not benefit employees and could be used by competitors and others to the detriment of the company.