On 15 January 2020, the U.S. Securities & Exchange Commission (SEC) released the latest proposed rule to implement Section 1504 of the Dodd-Frank Wall Street Reform and Consumer Protection Act. Section 1504 requires companies operating in the extractives sector and listed on US stock exchanges to disclose payments to governments. For more background on the SEC's drafting process, and criticism it received from anticorruption groups, see our previous story on the topic.

Publish What You Pay (PWYP) urged companies committed to the principles of the Extractive Industries Transparency Initiative (EITI) and listed on US stock exchanges to comment on the SEC's proposed rule. In an open letter, PWYP argued that this rule would deviate significantly from the EITI global transparency standard, particularly in its definition of project-level reporting, and "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."

PWYP invited 25 oil, gas and mining companies to answer the following two questions:

• 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 invited AngloGold Ashanti, ArcelorMittal, Barrick Gold, BHP, BP, Chevron, ConocoPhillips, Eni, Equinor, ExxonMobil, Freeport-McMoRan, Gold Fields, Hess Corporation, Hudbay, IAMGOLD, Kinross, Kosmos Energy, Marathon Oil, Newmont, Noble Energy, Petrobras, Rio Tinto, Shell, Total and Vale to respond. Their responses or non-responses are recorded below.