Further to our recent report: “Vanguard Releases Updated Voting Guidelines,” Cooley’s memo highlights prominent policy changes from the prior season, including, among other things, reinforced emphasis of financial materiality (including in the context of E&S proposals), less detailed and more principles-based expectations, and elimination of consideration of diversity-related demographic data to evaluate board composition.
Notably given the recent reorganization of its US investment advisory structure last June into these two wholly owned investment advisors, Cooley notes no substantive differences between Vanguard Capital Management and Vanguard Portfolio Management policies.
Note: Corporate issuers who are members of the Society can request a complimentary copy of Proxy Analytics’ more detailed memo summarizing Vanguard’s updated proxy voting guidelines via this email address.