September 27, 2007
On behalf of the Corporate Responsibility Committee of the School Sisters of Notre Dame, I write to express our opposition to any action by the Securities and Exchange Commission (SEC) to weaken the rights of Americans to present resolutions for votes by the millions of investors like me who own stock in companies. (This in reference to SEC File Number S7-16-07.)
We urge the SEC and, if necessary, Congress to stop any initiatives that would limit the rights of shareholders to sponsor proxy resolutions or prevent investors from nominating members of corporate boards. Our bottom line here is simple: We believe that it would be better for the SEC to take no action on their shareholder resolution initiatives than it would be for the Commission to destroy the rights of shareholders.
We believe there is a need for shareholder involvement in American corporations. We strongly support the rights of shareholders to use the resolution process to encourage responsible action by often troubled companies that engage in runaway CEO compensation, poor corporate governance, a history of polluting/inaction on climate change, racial/gender discrimination and other problem behaviors.
These problems often end up costing shareholders a lot of money in the long run as a result of lawsuits, clean-ups, damaged company reputations and other outcomes that drive stock prices down. The best remedy is when the companies in question are encouraged by shareholders to get on the right path and start acting as well governed, responsible corporate citizens. These are not companies that the SEC should be protecting from shareholders who are understandably concerned about what are often very serious risks to our long-term investments. These companies -- and, in fact, all companies -- need more scrutiny and feedback, not less.
We strongly oppose any move to take away shareholder rights to file advisory resolutions. Thank you for your attention to our comments.