From: Steve Gibbs [Steve.Gibbs@csb.gov.au]
Sent: Tuesday, June 17, 2003 11:18 PM
To: rule-comments@sec.gov
Subject: Proxy rules

Mr Dunn
Deputy Director
Securities and Exchange Commission

Dear Mr Dunn

We have recently become aware of the review which the SEC is undertaking 
of the proxy rules and regulations.

The Public Sector Superannuation Scheme (PSS) and Commonwealth Superannuation 
Scheme (CSS) are public sector pension funds in Australia which combined are 
the second largest in this country.  We manage A$10 billion of which 
approximately A$ 1.2 billion would be invested in listed US companies.

We strongly support the submissions and comments made by Hermes Investment 
Management Limited in their letter dated 10 June 2003 addressed to Mr Katz, 
and in their letter dated 13 June 2003 to yourself, which they have provided 
to me.

Changes in the rules applying in the US particularly allowing shareholders to 
'simply and cheaply put a resolution to an annual meeting to remove one or more 
directors' we see as essential governance reforms necessary in the United States.

Yours sincerely

Steve Gibbs
Chief Executive Officer
Public Sector & Commonwealth Super Schemes (PSS/CSS)
Tel 02 6263 6911
Fax 02 6263 6900


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