Forum Report:
Electronic Participation in Shareholder
Meetings
Standards for Fair Conduct of Shareholder Meetings
Using Electronic Communications
Note:
This report was prepared by the Shareholder Forum’s chairman with
the concurrence of its “E-Meetings”
Program Panel, members of which
may append individual comments. |
The stated purpose of the Shareholder Forum’s “E-Meetings” program was “to
develop marketplace standards for the fair and orderly conduct of
shareholder meetings that allow electronic participation.”
During the past six months Forum participants have observed communications
practices during the 2010 corporate annual meeting season, considered
issues raised by representatives of all interested corporate and investor
constituencies, directly tested communication technologies and processes,
exchanged views in an open meeting, and offered comments on various
practices as well as proposed standards.
This effort resulted in a broad consensus of Forum participants as well as
Program Panel members that investors could judge the
fairness of a company’s shareholder meeting communications – including
pre-meeting communications, and whether conducted by electronic or any
other means – based on three essential conditions.
A
company should provide all shareholders a reasonable opportunity,
before voting, to |
(1) |
ask management questions relating to
director elections and other matters to be decided at a shareholder
meeting, |
(2) |
present questions or views to
management publicly for consideration by other shareholders, and |
(3) |
observe any management or director
candidate responses to the questions other shareholders have chosen
to present publicly. |
It should be emphasized that these standards are intended for individual
investor application to specific company practices, and that differences
in investor views should be expected in these as well as all other
analyses. The Forum also deliberately avoided prescriptive classifications
of any practices or processes such as “pure virtual” or “hybrid” meetings,
partly because of concerns that categorical fairness labels could provide
excuses for abusive conduct but also because negative labels could
discourage well-intentioned experiments.
Finally, the establishment of standards for judging essential fairness
must be viewed in the context of the extraordinary opportunities presented
by modern communications technologies to improve investor access to the
information needed for both voting and capital commitment decisions. It
has been widely observed that the traditional function of an annual
meeting to convene shareholders for exchanges of information and
decision-making has been lost in an age of “proxy plumbing” that requires
voting decisions before the meeting. What may have been the most
significant result of the E-Meetings program was a universal appreciation
of the more natural “continuum communications” that are enabled by current
technologies to engage in truly useful pre-meeting information exchanges.
Shareholders can now seek information from a company’s management before
voting rather than in a post-vote Q&A ritual, and management can now find
out what interests shareholders in time to respond.
Members of the E-Meetings Program Panel may be appending their individual
comments to this report, and those statements will be distributed as they
become available. All Forum participants are of course invited to offer
their views relating to the standards, and to suggest examples of their
application.
GL – September 30, 2010
Gary Lutin,
Chairman
Program Panel:
Hye-Won Choi, TIAA-CREF
Margaret M. Foran, Prudential Financial, Inc.
Mary Beth Kissane, Walek & Associates and National Investor
Relations Institute (NIRI)
Cary I. Klafter, Intel Corporation
Alvin P. Kressler, III, Bloomberg
James Kristie, Directors & Boards
Eric Nowak, Swiss Finance Institute and European Group for Investor
Protection (egip)
David A. Silverman, Blue Harbour Group and New York Society of
Security Analysts (NYSSA)
Timothy Smith, Walden Asset Management
Frank G. Zarb, Jr., Katten Muchin Rosenman LLP
|