Comments on Substantial Implementation, Duplication, and Resubmission of Shareholder Proposals Under Exchange Act Rule 14a-8

[Release No. 34-95267; IC-34647; File No. S7-20-22]

Submitted Comments

(Click here for meetings with SEC officials)
Apr. 3, 2024 Tom Quaadman, EVP, Center for Capital Markets Competitiveness, U.S. Chamber of Commerce
Oct. 30, 2023 Sanford Lewis, Attorney
Oct. 25, 2023 Multiple Investors and Fiduciaries
Oct. 3, 2023 Dr. Ruth Shaber, Founder and President, Tara Health Foundation
Aug. 2, 2023 Anonymous
Jul. 19, 2023 Sanford Lewis, Director, Shareholder Rights Group
Nov. 4, 2022 U.S. Senator Thom Tillis
Oct. 11, 2022 Leonard K. Dzubikat, Assistant to the Assistant Manager, Warinka Industries LLC
Oct. 4, 2022 Sanford Lewis, Director, Shareholder Rights Group
Sep. 15, 2022 John A. Zecca, Executive Vice President, Chief Legal, Risk and Regulatory Officer, Nasdaq, Inc.
Sep. 15, 2022 Davis Polk & Wardell LLP
Sep. 13, 2022 Ted Allen, Vice President, Policy & Advocacy, Society for Corporate Governance
Sep. 12, 2022 James Copland, Senior Fellow & Director, Legal Policy, Manhattan-Institute.org
Sep. 12, 2022 Steven Rothstein, Ceres, Managing Director, Ceres Accelerator for Sustainable Capital Markets
Sep. 12, 2022 US SIF: The Forum for Sustainable and Responsible Investment
Sep. 12, 2022 Veris Wealth Partners
Sep. 12, 2022 Newground Social Investment
Sep. 12, 2022 The Sustainability Group
Sep. 12, 2022 Domini Impact Investments
Sep. 12, 2022 Investment Company Institute
Sep. 12, 2022 Boston Trust Walden
Sep. 12, 2022 Americans for Financial Reform Education Fund, American Federation of State, County and Municipal Employees (AFSCME), Communications Workers of America (CWA), Public Citizen, and U.S. Impact Investing Alliance
Sep. 12, 2022 Principles for Responsible Investment
Sep. 12, 2022 Trillium Asset Management
Sep. 12, 2022 U.S. Impact Investing Alliance
Sep. 12, 2022 Clean Yield Asset Management
Sep. 12, 2022 Anna Falkenberg, Executive Director, Socially Responsible Investment Coalition
Sep. 12, 2022 The Williams Companies, Inc.
Sep. 12, 2022 Praxis Mutual Funds and Everence Financial
Sep. 12, 2022 NACCO Industries
Sep. 12, 2022 Melanie Senter Lubin, NASAA President, Maryland Securities Commissioner
Sep. 12, 2022 Marcie Frost, Chief Executive Officer, California Public Employees' Retirement System
Sep. 12, 2022 David R. Burton, Senior Fellow in Economic Policy, The Heritage Foundation
Sep. 12, 2022 Maria Ghazal, Business Roundtable
Sep. 12, 2022 American Securities Association ,Nareit, National Association of Manufacturers, NIRI: The Association for Investor Relations, and U.S. Chamber of Commerce
Sep. 12, 2022 Victoria Rostow, Senior Vice President Deputy General Counsel, Nareit
Sep. 12, 2022 Union of Concerned Scientists
Sep. 12, 2022 Tom Quaadman, Executive Vice President, Center for Capital Markets Competitiveness, U.S. Chamber of Commerce
Sep. 12, 2022 As You Sow
Sep. 12, 2022 Jackie Cook, Director, Stewardship, Product Strategy and Development, Morningstar, Inc.; Andrew Spurr, Senior Analyst, ESG Voting Policy Overlay Team, Morningstar, Inc.; and Aron Szapiro, Head of Retirement Studies and Public Policy, Morningstar, Inc./Morningstar Investment Management, LLC
Sep. 12, 2022 Tom McCaney, Director, Corporate Social Responsibility, Sisters of St. Francis of Philadelphia
Sep. 12, 2022 Chris Netram, Managing Vice President, Tax and Domestic Economic Policy, National Association of Manufacturers
Sep. 12, 2022 JoAnn Hanson, President, Church Investment Group
Sep. 11, 2022 James McRitchie, Shareholder Advocate, Corporate Governance
Sep. 11, 2022 Rick Alexander, CEO, The Shareholder Commons
Sep. 10, 2022 Julie Hammerman, CEO, JLens
Sep. 9, 2022 Carola van Lamoen, Head of Sustainable Investing, Managing Director, Robeco
Sep. 9, 2022 Josh Zinner, CEO, Interfaith Center on Corporate Responsibility
Sep. 9, 2022 John C. Harrington, President &, CEO, Harrington Investments, Inc.
Sep. 9, 2022 Sean O'Brien, General President, International Brotherhood of Teamsters
Sep. 9, 2022 Diana Kearney, Senior Legal and Shareholder Advocacy Advisor, Oxfam America
Sep. 9, 2022 Laura Campos, Director, Corporate & Political Accountability, Nathan Cummings Foundation
Sep. 9, 2022 Brandon Rees, Deputy Director, Corporations and Capital Markets, AFL-CIO
Sep. 9, 2022 Lori E.L. Ziebart, President and CEO, Energy Infrastructure Council
Sep. 9, 2022 Dieter Waizenegger, Executive Director, SOC Investment Group
Sep. 8, 2022 Fran Teplitz, Executive Co-director: Business, Investing & Policy, Grfeen America
Sep. 8, 2022 Rob Fohr, Director of Faith-Based Investing and Corporate Engagement, Presbyterian Church U.S.A.
Sep. 8, 2022 Dominican Sisters
Sep. 7, 2022 Catherine Rowan, Director, Socially Responsible Investments, Trinity Health
Sep. 7, 2022 Thomas P. DiNapoli, NYS Comptroller
Sep. 2, 2022 Jeannie Egbert
Aug. 30, 2022 Holly Testa, Director, Shareowner Engagement, First Affirmative Financial Network, LLC
Aug. 25, 2022 Jeffrey P. Mahoney, General Counsel, Council of Institutional Investors
Aug. 25, 2022 Luke
Jul. 25, 2022 Sanford Lewis, Director, Shareholder Rights Group
Jul. 13, 2022 Scott Jordan, Private Investor
Jul. 13, 2022 Jamie Bell, Retail Investor

Meetings with SEC Officials

(Click here for submitted comments from the public)
Aug. 11, 2023 Memorandum from the Office of Public Engagement regarding an August 4, 2023 virtual meeting with Labor Organizations
Mar. 10, 2023 Memorandum from the Division of Corporation Finance regarding a March 9, 2023 meeting with representatives of the Society for Corporate Governance
Mar. 6, 2023 Memorandum from the Division of Corporation Finance regarding a March 6, 2023 meeting with representatives of the American Federation of Labor and Congress of Industrial Organizations, and Shareholder Rights Group
Mar. 6, 2023 Memorandum from the Office of Commissioner Mark T. Uyeda regarding a March 3, 2023 meeting with representatives of the Society for Corporate Governance
Feb. 28, 2023 Memorandum from the Office of Commissioner Jaime E. Lizárraga regarding a February 28, 2023 meeting with the California Public Employees’ Retirement System
Feb. 24, 2023 Memorandum from the Office of Public Engagement regarding a February 10, 2023 meeting with various Investor and Advocacy Organizations
Feb. 24, 2023 Memorandum from the Office of Commissioner Hester M. Peirce regarding a February 6, 2023 meeting with the Society for Corporate Governance
Dec. 22, 2022 Memorandum from the Office of the Chair regarding a December 22, 2022 virtual meeting with representatives of the Advocates
Nov. 30, 2022 Memorandum from the Office of Commissioner Jaime Lizárraga regarding an October 6, 2022 meeting with representatives of US SIF
Sep. 9, 2022 Memorandum from the Division of Corporation Finance regarding an August 18, 2022 meeting with representatives of the Investment Advisers Association
Sep. 9, 2022 Memorandum from the Division of Corporation Finance regarding an August 18, 2022 meeting with representatives of the Society for Corporate Governance
Aug. 22, 2022 Memorandum from the Office of Commissioner Hester Peirce regarding an August 22, 2022 meeting with representatives of the Society for Corporate Governance
Aug. 8, 2022 Memorandum from the Office of the Chair regarding an August 5, 2022 discussion with the Rule 14a-8 Investor Working Group
Jul. 20, 2022 Memorandum from the office of Commissioner Hester M. Peirce regarding a July 20, 2022 meeting with representatives of the Manhattan Institute
Jul. 14, 2022 Memorandum from the Office of the Chair regarding a July 14, 2022 meeting with representatives of the Shareholder Rights Group