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Potential SEC disclosure considerations related to vaccine mandates

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Nov 30, 2021

The Department of Labor’s Occupational Safety and Health Administration (OSHA) published its final rule on November 5, which generally requires, among other things, employees to be vaccinated or start testing by January 4, 2022, with an earlier (December 5, 2021) enforcement date regarding the rule’s mask mandate, among other requirements for employers.

In light of these developments, public companies are contending with their planned compliance with these rules and how to disclose the potential material effects of such requirements in their Securities and Exchange Commission (SEC) filings. While we anticipate disclosures to continue to evolve and be fluid in this area, below is a current snapshot of some of the disclosures that companies are making in this area.

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Correction list for hyphenation

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