According to Morrow Sodali’s report: “Challenges under Rule 14a-8: 2023 season-end summary,” while no-action requests declined by a significant 24% this proxy season as compared to the 2022 season (which the report attributes in large part to SLB No. 14L), staff granted requests to exclude the proposal from the proxy statement at a much higher rate—46% this season vs. 28% last season.
Procedural challenges led the bases for exclusion at 46%, followed by ordinary business exclusions, at 35%, as shown here:
This compares to 35% (procedural) and 29% (ordinary business) exclusions, respectively, for the 2022 proxy season.
The information for the 2023 proxy season is based on annual meetings between July 1, 2022, and June 30, 2023. The information for the 2022 proxy season is based on annual meetings between July 1, 2021, and June 30, 2022.