- Presumably in response to the SEC’s recent Schedule 13G guidance (reported on here and here), the updated policy no longer provides specific potential voting outcomes on director elections or otherwise, but rather articulates its views on corporate governance best practices and long term value creation.
- The updated policy reflects a case-by-case evaluation of board composition (including consideration of whether the board reflects a diversity of backgrounds, experiences, and perspectives) with due deference to the processes and judgment of the company’s nominating committee.
- Consistent thematically with recent updates to BlackRock’s and Vanguard’s voting guidelines, specific board gender, racial, and ethnicity-focused diversity expectations were removed from the updated policy.
- State Street will look to director time commitment disclosure and the company’s underlying nominating committee practices and processes in lieu of imposing numerical limits on board service.
- Companies are expected to disclose sustainability-related risks and opportunities that they deem material to their businesses consistent with applicable local regulatory requirements and any company-adopted voluntary standards and frameworks.
Courtesy of Proxy Analytics’ diligence, State Street also made significant changes to its website, including removing from its Asset Stewardship Report webpages its Global Proxy Voting and Engagement Guidelines for Environmental and Social Factors, Global Issuer and Stakeholder Engagement Guidelines, and all quarterly stewardship reports and case studies, and removal of previous references to engagement on environmental and social issues, including Climate Risk Management, Human Capital Management, and Diversity, Equity & Inclusion.
Stay tuned for further analysis.
This post first appeared in the weekly Society Alert!