Our success is built on our clients’ success. We have a long and distinguished history of supporting our clients wherever they do business, from major financial centers to emerging and growth markets. We represent many of the world’s leading corporations and major financial institutions, as well as emerging growth companies, governments and state-owned enterprises, often working on ground-breaking, precedent-setting matters. With a deep understanding of our clients' businesses and the industries they operate in, our work is driven by their need for outstanding legal and commercial advice.
Shareholder proposals relating to ESG matters are frequent targets for exclusion by companies, and based upon a survey of the no-action letters submitted during the 2019 proxy season, this trend continues.
To print this article, all you need is to be registered or login on Mondaq.com.
Shareholder proposals relating to ESG matters are frequent
targets for exclusion by companies, and based upon a survey of the
no-action letters submitted during the 2019 proxy season, this
trend continues. Over 40% of the no-action letters we reviewed for
the 2019 proxy season related to a variety of ESG matters, and the
arguments and outcomes in those letters are instructive as to how
companies and the SEC staff are approaching ESG proposals,
especially in the wake of recent SEC staff guidance on its approach
to requests based on the "economic relevance" and
"ordinary business" exemptions which are frequently cited
grounds for excluding ESG-related shareholder proposals.
The content of this article is intended to provide a general
guide to the subject matter. Specialist advice should be sought
about your specific circumstances.
Shareholder Proposals 2019 – ESG No-Action Letter Trends
United StatesCorporate/Commercial Law
Contributor
Our success is built on our clients’ success. We have a long and distinguished history of supporting our clients wherever they do business, from major financial centers to emerging and growth markets. We represent many of the world’s leading corporations and major financial institutions, as well as emerging growth companies, governments and state-owned enterprises, often working on ground-breaking, precedent-setting matters. With a deep understanding of our clients' businesses and the industries they operate in, our work is driven by their need for outstanding legal and commercial advice.
