Shearman And Sterling

Woman walking in lobby of office building -- Shareholder Proposals

September 20, 2019

Shareholder Proposals 2019 – ESG No-Action Letter Trends


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Shareholder proposals relating to ESG matters are frequent targets for exclusion by companies, and based upon a survey of the no-action letters submitted during the 2019 proxy season, this trend continues. Over 40% of the no-action letters we reviewed for the 2019 proxy season related to a variety of ESG matters, and the arguments and outcomes in those letters are instructive as to how companies and the SEC staff are approaching ESG proposals, especially in the wake of recent SEC staff guidance on its approach to requests based on the “economic relevance” and “ordinary business” exemptions which are frequently cited grounds for excluding ESG-related shareholder proposals.

Read “Shareholder Proposals 2019 – ESG No-Action Letter Trends.”

Authors and Contributors

Richard Alsop


Capital Markets

+1 212 848 7333

+1 212 848 7333

New York