December 23, 2020
Re: File No. SR-NASDAQ-2020-081
Dear Ms. Countryman:
Brightcove appreciates the opportunity to submit this letter in response to the Securities and Exchange Commissions request for comments regarding the NASDAQ Stock Markets new proposed listing rules to advance corporate board diversity.
We want to offer our unqualified support for this proposal and NASDAQs thoughtful approach to its implementation. We believe more diverse corporate boards are in the best interests of the companies they serve, their shareholders, and their customers. When a leadership team reflects the rich diversity of the marketplace, the perspective they bring benefits everything from corporate governance to new product development and bolsters investor confidence.
Furthermore, we applaud the proposals disclosure-based approach and its very reasonable time frame for compliance. Investors need the transparency in board diversity data that is central to this initiative, and we have no doubt that providing the required disclosures will not be burdensome for Brightcove in any way. Having a phase-in period will give companies the time they may need to amend their governing documents or obtain the approval of their shareholders, and offering non-compliant companies an opportunity to explain why they do not meet the proposals minimum of two diverse directors reflects NASDAQs commitment to developing a policy that is eminently reasonable and fair.
At Brightcove, we know that the wide-ranging perspective of a diverse board is a distinct competitive advantage, and were proud that our nine-member board includes five women and two minority members. NASDAQs proposal will help make meaningful progress toward board diversity in regards to race, ethnicity, sexual orientation, and gender identity. And we have seen firsthand that more diverse boards will better serve their companies and the people who invest in them.
Sincerely,
Jeff Ray
CEO, Brightcove