Further to our recent report on the New York State Comptroller’s request for good faith engagement on shareholder proposals in lieu of companies’ unilateral exclusion, the Interfaith Center on Corporate Responsibility and Shareholder Rights Group similarly requested companies that intend to exclude a proposal in the absence of SEC staff feedback reconsider their exclusion determinations after engaging with proponents to avoid the risk of director “no-vote” campaigns, floor proposals, public campaigns, and/or litigation. The statement notes that investors remain willing to consider withdrawing their proposals based on successful engagements.