Last year, we reviewed proxy statements filed by companies in the Silicon Valley 150[1] (SV150) to see whether they included an officer exculpation proposal[2] in their proxy statements for stockholder meetings held from August 1, 2022, through July 31, 2023 (“Year One”). As reflected in our previous post and Client Alert, during Year One, only nine SV150 companies included an officer exculpation proposal in their proxy statements, of which seven passed and two failed.Continue Reading Officer Exculpation and the Silicon Valley 150: Year Two
Corporate Governance
SEC, California, and CSRD Climate Disclosure Requirements Comparison Tool
Our recent Client Advisory provides a comparison tool to assist companies in determining whether they fall within the scope of the SEC’s final climate disclosure rules (currently stayed pending review of legal challenges), the California climate disclosure laws (Senate Bills 253 and 261 and Assembly Bill 1305), and the European…
Continue Reading SEC, California, and CSRD Climate Disclosure Requirements Comparison ToolSEC Pauses Climate-Related Disclosure Rules Amid Legal Challenges
Our recent Client Alert discusses that on April 4, 2024, the U.S. Securities and Exchange Commission (SEC) published an order staying the final climate-related disclosure rules[1] pending completion of judicial review of the consolidated legal challenges in the U.S. Court of Appeals for the Eighth Circuit. Notwithstanding the stay…
Continue Reading SEC Pauses Climate-Related Disclosure Rules Amid Legal ChallengesWebinar Recording Now Available | The SEC’s Climate-Related Disclosure Rules
On March 6, 2024, the U.S. Securities and Exchange Commission (SEC) voted to adopt final rules requiring disclosure of climate-related information in registration statements and annual reports, by both domestic registrants and foreign private issuers. The final rules are comprehensive, detailed, and intended to encourage consistent comparable, and reliable disclosure of climate-related information.Continue Reading Webinar Recording Now Available | The SEC’s Climate-Related Disclosure Rules
Delaware Court of Chancery Addresses Validity of Stockholder Agreement-Based Restrictions over Corporate Governance Matters
Our recent Client Alert discusses a February 23, 2024, decision issued by Vice Chancellor J. Travis Laster of the Delaware Court of Chancery concluding that some provisions of a stockholder agreement purporting to give a large stockholder various governance rights—here, in the public company and investment bank Moelis—violated the Delaware statute by infringing upon the authority of the board of directors and were therefore invalid. Reviewing Delaware case law on board authority dating back to the early twentieth century, the court determined that the offending provisions—set forth in a stockholder agreement and not in the certificate of incorporation—operated as an improper constraint on board authority in violation of Section 141(a) of the Delaware General Corporation Law and interfered with the board’s authority to use its best judgment on management matters and policy. At the same time, the court concluded that some of the rights in question—particularly, the requirement to nominate the founder’s nominees for election and to use reasonable efforts for such nominees to be elected and to continue to serve as directors—were not facially invalid because they could operate legitimately under Delaware law. In particular, the court noted that stockholders have a fundamental right to nominate directors and that the corporation could appropriately take efforts, such as including the nominees in its proxy materials and on its proxy card, to cause the founder’s nominees to be elected and to serve on the board. Continue Reading Delaware Court of Chancery Addresses Validity of Stockholder Agreement-Based Restrictions over Corporate Governance Matters
Preparing for the 2024 Proxy Season
Our recent Client Alert discusses applicable rule changes, guidance, and disclosure considerations for the 2024 proxy season, as well as reminders for what is on the horizon for public company governance and disclosure. It covers the following topics:Continue Reading Preparing for the 2024 Proxy Season
NYSE Relaxes Shareholder Approval Requirements for Equity Sales to Substantial Security Holders
Our recent Client Alert discusses the SEC’s approval of the NYSE’s proposed rule change narrowing the circumstances under which a listed company must obtain shareholder approval for a sale of securities to holders of five percent or more of either the common stock or voting power of the company. The…
Continue Reading NYSE Relaxes Shareholder Approval Requirements for Equity Sales to Substantial Security Holders2023 Silicon Valley 150 Corporate Governance Report
We are pleased to share our 2023 Silicon Valley 150 Corporate Governance Report, which reviews the corporate governance practices and disclosures of the Valley’s largest public companies. The report includes information regarding board matters, officer matters, defensive measures, proxy statement disclosures, environmental, social, and governance (ESG) and sustainability reporting, stockholder proposals, activism, and executive compensation of the SV150 companies.
Continue Reading 2023 Silicon Valley 150 Corporate Governance Report
Form 10-K Reminders
Our recent Client Alert provides helpful reminders as preparations for annual reports on Form 10-K get under way. For calendar-year companies, upcoming Form 10-K filings will be required to include new cybersecurity disclosure and clawback disclosure, including two cover page checkboxes relating to accounting errors and clawbacks and the company’s…
Continue Reading Form 10-K RemindersISS Releases 2024 Benchmark Policy Updates
On December 19, 2023, ISS Governance announced updates to its 2024 benchmark proxy voting policies. The full text of the updated benchmark policies for 2024 should be available later this month and will generally apply to shareholder meetings held on or after February 1, 2024.