On February 3, 2023, the US Securities and Exchange Commission (SEC or Commission) announced that video game developer Activision Blizzard, Inc. (Activision) agreed to pay $35 million to settle charges for its failure to maintain adequate disclosure controls and for violation of an SEC whistleblower protection rule. The settlement marks the end of a headline-making probe into the company's handling of employee harassment complaints and workplace misconduct allegations.
A key takeaway from the Activision settlement is the extension of the rule regarding disclosure controls to address what might typically be thought of as an HR-only issue. In its order (the Order), the SEC contrasted risk factor disclosures in Activision's SEC filings between 2018 and 2021 "acknowledg[ing] that attracting, retaining, and motivating a workforce of employees with specialized skills is particularly important to its business," with Activision's failure to maintain "controls and procedures designed to ensure that information related to employee complaints of workplace misconduct would be communicated to [Activision]'s disclosure personnel to allow for timely assessment on its disclosures." The emphasis on Activision's failure to collect what the SEC views as relevant information about employee concerns to assess the accuracy of risk factor disclosures is an interesting indication of where the Commission may go in the future. While the Order does not assert that Activision's disclosures were ...
The Ghana Museums and Monuments Board (GMMB) has issued a formal apology to Professor Wazi Apoh, Dean of the School of Arts and Professor of Archaeology at the University of Ghana, following the c...