DragonGC’s new report: “Developments since the SEC issued SLB 14M; Research tool for making “ordinary business” and “economic relevance” arguments” flags 16 no-action requests based on 14a-8(i)(7) (ordinary business) and/or 14a-8 (i)(5) (economic relevance) that specifically cite new SLB 14M, eight of which include a detailed “micromanagement” argument. No-action letters are listed by company, stated grounds for relief, proponent, and proposal type, and include a link to the no-action letter.The report aims to help educate and inform companies’ positions going forward.
See “SEC allows five firms to block lobbying proposals” (Responsible Investor).
This post first appeared in the weekly Society Alert!