From: BUSH Tim [T.Bush@hermes.co.uk]
Sent: Friday, November 21, 2003 9:27 AM
To: 'rule-comments@sec.gov'
Subject: S7-19-03

From a UK perspective the debate on S7-19-03 is interesting. But fortunately
not business critical, quite the opposite.

Claims of the kind that shareholders nominees could be the "end of the world
as we know it", are not only wrong as were the "no" cases for votes for
women, black civil rights etc, but potentially disastrous for the US as a
jurisdiction for a long-term capital market.

Capital is mobile. If the US continues to have substandard rights for
shareowners, capital will migrate to places where rights are stronger. 

Compare: BP (UK) vs Exxon (US) . Similar global footprints interms of
customers and production, but wholly different approaches to dealing with
shareholders. One has to listen to to shareholders, the other does not need
to. I know which one I would prefer to invest in. 


Tim Bush FCA



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