Jan. 30, 2020
Comment on File Number File No. S7-23-19 To: Vanessa A. Countryman, Secretary, Securities and Exchange Commission From: John Chevedden Date: January 30, 2020 Re: Comment on File Number File No. S7-23-19 It has been reported that governance shareholder proposals average 40%-support. And the 40%-support is an understated figure because such proposals are almost universally opposed by management and management has a lot influence on the vote. Plus many shareholders do not have access to independent proxy voting advice and thus automatically follow the negative management recommendation. Plus some companies use shareholder money to advertise against shareholders proposals. Plus a number of companies, like Lockheed Martin, publish a shareholder proposal in a pejorative manner. For instance Lockheed Martin invented its own watered-down title for a shareholders proposal, introduced the proposal with opposition text, put a negative image next to the proposal and followed the proposal with an opposition statement.