Jan. 21, 2020
Hello,
I’m writing in support of the existing rule 14-a guidelines. I think that changing the ownership threshold and period, as well as the vote thresholds for resubmission, will limit shareholder’s rights and ultimately harm the performance of publicly traded companies. Many resolutions that received a small vote the first or second time they were submitted have seen increased shareholder support or were withdrawn because companies’ agreed to implement some of all of the shareholder requests.
Please do not disenfranchise shareholders, especially the mid-size institutional investors that helped constructively engaged with publicly traded companies for 50 years. Shareholder resolutions are a critical avenue for investors to communicate with and help companies improve their governance and ESG profiles. Organizations like the ICCR have had a genuinely positive impact on corporate culture and governance and it would be a tragedy to halt all the progress that has been made.
Thank you,
Russell Heller
Russell Heller
Associate Consultant
Bain & Company | 1114 Avenue of the Americas, 43rd Floor | New York, NY 10036 | United States
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