...As an EITI-supporting company, your company has agreed to "[p]ublicly declare support for the EITI Principles and, by promoting transparency throughout the extractive industries, help public debate and provide opportunities for sustainable development."...The SEC's proposed rule...would deviate significantly from that global transparency standard...Most notably, the SEC's draft rule proposes a definition of "project-level" reporting that would allow companies to artificially aggregate payments to the sub-national or national levels across multiple separate projects, rather than using the contract-based approach for defining project-level payments embedded in the EITI Standard.

...Recognizing the importance of detailed information to better enable stakeholders to understand and monitor revenue payments, the EITI Board updated the EITI Standard to include disaggregated (contract-based) project-level reporting. The SEC's proposed approach...would represent a regressive step, making the payments reported by US-listed companies much less useful to investors, government officials, journalists, civil society, ordinary citizens, and others...the SEC's proposed rule, if adopted in its current form, would be a marked step backwards in the global movement to ensure that stakeholders have access to relevant information about the extraction and sale of their country's natural resource wealth.

Does your company support the EITI Standard's definition of project-level reporting? Do you agree that this definition should be adopted by the SEC in its final rule?

...We also urge your company, as a supporting member of the EITI, to use this critical opportunity to submit a comment to the open rulemaking to request that the SEC produces a final rule that is consistent with the 2019 EITI Standard...