Tag Archives | Substantial Implementation

‘Substantial Implementation’ Will Backfire

Substantial implementation, that’s the deception companies have been arguing in order to obtain ‘no-action’ relief under SEC Rule 14a-8(i)(10) after implementing proxy access ‘lite.’ Law firms have been touting recent no-action letters released on February 12, with more in March  2016. It looks like a clear win for entrenched managers and directors for implementing only proxy […]

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Apple Shareholders Rejected Real Proxy Access

Apple Shareholders Rejected Real Proxy Access

Apple shareholders rejected real proxy access at their meeting on February 25, 2016. Maybe shareholders thought they already have it. Recent decisions by the SEC could lead shareholders to believe proxy access was “substantially implemented.” Maybe they wanted to support Apple’s management while the company is under attack from the FBI.   ISS recommended a […]

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Substantial Implementation

Substantial Implementation: Proxy Access Lite

Substantial implementation, that’s what SEC staff deemed proxy access ‘lite’ last week. Investor rights were eroded again as staff granted a number of no-action letters on February 12th to companies based on “substantial implementation” of proxy access. At its founding, the SEC was largely a champion of shareholder rights. The SEC required companies to include proposals […]

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