The following Letter Type G, or variations thereof, was submitted by individuals or entities.
Letter Type G:
Dear Commissioner Cox:
We, the Benedictine Sisters of Mount St. Scholastica, have long believed in the process of shareholder advocacy. We have participated in shareholder actions for many years. We have engaged companies about their policies and practices. This has had beneficial results for both groups.
I. Thresholds for Resubmission
Our response: We oppose these thresholds for resubmission.
II. Nomination to the Board
The second proposal would allow shareholders to nominate on the proxy, BUT only if investors with 5% of the shares of the company banded together to present the nomination. This 5% level of shares required to nominate a Director is onerous.
Our response: We oppose the prohibition on nominations of directors in the first proposal, and oppose the 5% threshold in the second proposal.
III. The Electronic Petition Model
Our response: However, chat rooms and electronic forums must be additional tools of communication, combined with the existing right to file a resolution through the proxy process. We cannot support a substitution of one for the other.
IV. The Opt-out Option
Our response: We, as socially responsible investors, would be opposed to any opportunities for companies to opt-out.
The severe curbs on shareholder input process put forward by the SEC are unacceptable. There is no documented problem or problems that would justify such extreme restrictions on shareholder rights. It would be better for the SEC to take no action on their shareholder resolution initiatives than it would be to irreparably harm a process that effectively informs our civic economy. In a democratic society, there needs to be more tools to engage with companies rather than less. The stockholder resolution has been such a tool since 1934.