June 26, 2007
Dear Chairman Cox:
Mr. Christopher Cox
Securities and Exchange Commission
100 F Street, NE
Washington, D.C. 20549
Dear Commissioner Cox:
On behalf of the Adrian Dominicans Sisters, a community of vowed religious women based in Michigan, I write to express concern that Securities and Exchange Commission is apparently considering to propose elimination of the right of shareholders to file non-binding resolutions at corporations. For over three and a half decades, shareholder proposals have provided large and small shareholders with a voice in the governance of corporations on which their financial futures depend. Doing away with these proposals would be a setback for shareholder democracy and corporate governance more generally.
The Adrian Dominican Sisters have a commitment of over thirty years to corporate responsibility and socially responsible investing. As responsible stewards, we have been actively involved in integrating environmental, social and governance issues into our investment decisions. We view the role of engaged shareholders as an important aspect of the civic infrastructure, making significant contributions to the ongoing dialogue regarding the role of corporations in the global economy.
Precatory resolutions are non-binding, and have strict restrictions regarding subject matter and formatting. Thus they do not create burdensome requirements on management. Eliminating this right would remove an important tool of management accountability to shareholders. We would strongly oppose any effort to curtail this important component of shareholder democracy.
We urge the SEC to drop this concept before it gets to the proposal stage.
Coordinator of Corporate Responsibility
Adrian Dominican Sisters