"US Corporate Governance: Boards of Directors Face Increased Scrutiny"

by Skadden, Arps, Slate, Meagher & Flom LLP

In many ways, corporate governance in 2013 looked similar to corporate governance in 2012. Most public company directors were re-elected with shareholder support in excess of 90 percent of votes cast and only a handful of directors failed to achieve majority support. Most companies received strong support in their say-on-pay votes. And many shareholder proposals on topics such as board declassification, majority voting for directors in uncontested elections and elimination of supermajority vote requirements in corporate charters and bylaws continued to attract significant shareholder support.

Nevertheless, a number of developments in 2013 continued the paradigm shift from board-centric to shareholder-centric governance of public companies. These developments involved activist investors, governance activists such as state and labor pension funds, mutual funds and other traditional long-term investors or combinations of these market participants. And every indication is that this paradigm shift will continue to increase the scrutiny on boards of directors — including with respect to board composition and boards’ substantive business and strategic decisions.

The Framework of Director Elections. Institutional investors and governance activists have largely succeeded, at least at S&P 500 companies, in changing the election framework so that most directors stand for election annually (rather than once every third year) and must submit their resignation if they fail to receive majority support from shareholders. As a result, the re-election of directors can no longer be taken for granted, and shareholder concerns need to be considered in a company’s assessment of an upcoming proxy season. Notable trends and events include:

  • Almost 90 percent of S&P 500 companies (and almost 60 percent of Russell 3000 companies) have annually elected boards. The Harvard Shareholder Rights Project led a campaign in 2012 and 2013 to wipe out classified boards, getting almost 100 large companies to declassify; shareholder proposals to declassify received average shareholder support of 79 percent in 2013.
  • Approximately 90 percent of S&P 500 companies (and approximately 46 percent of Russell 3000 companies) have a majority voting standard in director elections and/or a policy requiring resignation if a director fails to get majority support; shareholder proposals on this topic received average shareholder support of 58 percent in 2013.
  • Shareholder efforts to declassify boards of directors and to expand majority voting/resignation policies will continue in 2014 and will migrate to companies outside the S&P 500. Vanguard, a significant shareholder at many public companies, recently launched a letter-writing campaign, targeting approximately 350 companies, encouraging them to declassify their boards, adopt majority voting and give shareholders the right to call special meetings. Although Vanguard describes its approach as “quiet diplomacy,” Vanguard’s efforts on these issues may be difficult for companies to ignore.

“Vote-No” Campaigns. Although vote-no campaigns against directors are not a new phenomenon, they were more effective in 2013 than in previous years. Based on Institutional Shareholder Services (ISS) data, there were vote-no campaigns against 15 directors in 2013, resulting in average votes of 59 percent in favor and 41 percent against targeted directors. Although many of these directors were re-elected, even under majority voting standards, the relatively low level of shareholder support in some cases achieved the campaigns’ desired result. Although the number of attempts likely will be limited, vote-no campaigns will continue to be part of the landscape in 2014. Two of the more noteworthy campaigns were:

  • Hewlett-Packard: CtW Investment Group (a labor pension fund-affiliated group) led a vote-no campaign arising from HP’s acquisition of Autonomy Corp. and subsequent write-off. The campaign focused on the finance and investment committee chair and the audit committee chair, each of whom received more than 40 percent negative votes and (even though re-elected) resigned from the board. Also, the non-executive chairman received more than 40 percent negative votes and remained on the board but resigned as chair. In July, HP added three new directors.
  • JPMorgan Chase: CtW Investment Group led a vote-no campaign against members of JPMorgan Chase’s risk committee and the chair of the audit committee. The three risk committee members received 40 percent or greater negative votes, and two of them resigned. In September, JPMorgan Chase added two new directors.

Proxy Access. With many companies having annually elected directors and a meaningful (rather than symbolic) ability to vote against directors, a number of institutional investors look at proxy access as the next important step in the evolution of the director election framework. Proxy access would allow qualifying shareholders to nominate a limited number of director candidates and have those candidates appear in company proxy materials, alongside the board’s nominees, presumably making it easier for investors to elect candidates they favor over the board’s nominees. A consensus among institutional investors appears to be emerging to support proxy access proposals modeled on the vacated SEC rules. Those proposals allow a group of shareholders holding 3 percent or more of a company’s shares for at least three years to include in company proxy materials candidates for up to 20 or 25 percent of the total number of board seats. Notable developments include:

  • Pursuant to an agreement for the withdrawal of a proxy access shareholder proposal in 2012, Hewlett-Packard proposed a proxy access bylaw amendment for shareholders holding 3 percent of HP stock for three years to nominate candidates for 20 percent of the board; the bylaw was approved by holders of 68 percent of the shares outstanding.
  • Western Union negotiated the withdrawal of a one-year/1 percent proxy access shareholder proposal in 2013 by adopting a three-year/3 percent proxy access bylaw.
  • Nonbinding shareholder proposals to adopt proxy access with three-year/3 percent standards and relating to either 20 or 25 percent of the board seats achieved majority shareholder support at CenturyLink (72 percent of votes cast), Darden Restaurants (62 percent of votes cast) and Verizon Communications (53 percent of votes cast). Recently, in response to this shareholder support, Verizon announced the adoption of a proxy access bylaw, subject to shareholder approval at the company’s 2014 annual meeting.
  • Significantly, the universe of proponents of proxy access shareholder proposals is expanding. The proxy access proposal at Darden Restaurants was proposed by the Nathan Cummings Foundation. At a recent panel discussion, a representative of Nathan Cummings indicated the foundation was likely to submit at least three proxy access proposals in the 2014 proxy season. In addition, CtW Investment Group, which has a history of governance activism and running vote-no campaigns, has proposed a three-year/3 percent proxy access proposal for Walgreen’s 2014 annual meeting. These developments may portend an increase in three-year/3 percent proxy access shareholder proposals, and if 2013 voting trends continue many of these are likely to receive majority support.

Board Composition. The developments described above share a fundamental theme — making director elections more meaningful so as to give shareholders greater ability to influence the composition of the board. Where all is going well, shareholders may be content to defer to the judgment of a nominating committee consisting of independent directors and, ultimately, to the board to ensure that the board is comprised of men and women with the relevant skills, experiences and independence, as a group, to ably oversee and direct company management. Where shareholders perceive the company to be off course — languishing stock price, ill-conceived strategy or acquisitions, illegal or scandalous corporate actions, poor executive compensation practices or otherwise — or perhaps at increased risk of heading off course, that deference can dissipate and shareholders may ask themselves whether the team in the boardroom is the right one. The factors institutional investors focus on include:

  • Directors’ Skill Sets: Since the 2010 proxy season, companies have been required to discuss in their proxy statements the specific experience, qualifications, attributes or skills that led to the conclusion that a person should serve as a director. Over time, some companies’ disclosures have become more detailed or elaborate, using skill matrices or other graphic representations to reflect the quality and diversity of skills and experiences in the boardroom. We anticipate continued investor scrutiny as to whether boards have the right skills relative to a company’s business and competitive circumstances.
  • Diversity: While board diversity includes having directors with a range of skills and experiences, it also includes racial and gender diversity. Gender diversity in the boardroom continues to be an area of particular focus, in the U.S. and internationally. The European Union is considering legislation that would require large public companies in which women comprise less than 40 percent of the non-executive directors to give priority to female candidates and permit sanctions for noncompliance. Although it is unlikely that such a scheme would be considered in the U.S., various institutional investors and other groups have touted data suggesting that companies with gender-diverse boards have better performance. Many of these investors, together with women’s groups and others, formed the Thirty Percent Coalition, which has been engaged in letter-writing campaigns and has submitted shareholder proposals seeking commitments from companies to increase gender diversity on their boards. We expect these efforts to continue.
  • Director Tenure: Long-tenured directors present a quandary for some institutional investors. On the one hand, these directors can bring to the boardroom significant experience and familiarity with a company and an industry. At the same time, some investors are concerned that long-tenured directors may lack independence or objectivity and that the absence of director turnover comes at the expense of introducing fresh perspectives into the boardroom. The Council of Institutional Investors added a provision to their corporate governance policies that boards should consider director tenure when making independence determinations. ISS has been engaged in a dialogue with market participants on this topic but did not change its 2014 voting policies to incorporate any position on director tenure. ISS has decided to engage in additional market participant outreach and may consider voting policy changes relating to director tenure in the future. A number of non-U.S. jurisdictions already have adopted guidelines or requirements aimed at limiting director tenure. We anticipate that boards’ consideration of director tenure — both in terms of individual directors and average tenure for the full board — will increasingly become an important topic. We expect institutional investors will want to engage with lead directors and nominating committee chairs to discuss director tenure, and that, over time, companies may consider proxy disclosure to preemptively address investor questions on this topic.

Activism and the Second-Guessing of Board Business Decisions. Traditional institutional investors understand that they do not necessarily know better than the board and management how a particular company should manage its businesses. But, perhaps more so than ever before, where a company has had long-term underperformance, institutional investors have become much more open to hearing from, and supporting, “activist” investors who have amassed significant investments in companies and who purport to know better than management and the incumbent board the steps a company should be taking to increase shareholder value.

Shareholder activism in the U.S. has increased significantly over the past several years, and activists now often target large, well-known companies once thought to be sufficiently large so as to be immune to these efforts. Although every activist campaign is unique, an increasing number of instances involve activists presenting operational and longer-term strategic changes rather than short-term financial gimmickry. Increasingly, activists are hiring experienced financial, legal and public relations advisers and are nominating candidates for boards who bring significant industry expertise and other strong credentials.

In one of the more interesting developments of the past year, a shareholder activist and a traditional institutional investor directly and very publicly teamed up to push a company to make an important strategic change. Relational Investors and the California State Teachers’ Retirement System (CalSTRS) joined efforts to advocate that Timken Company separate its steel business from its bearings business. Relational presented its views to Timken management and CalSTRS submitted a 14a-8 shareholder proposal requesting that the company engage an investment bank to effectuate a spin-off of the steel business. That proposal received the support of 53 percent of the votes cast at the annual meeting and, shortly thereafter, Timken announced that the board had created a strategy committee to explore the separation of the steel business and the committee had retained an investment banker. In early September, Timken announced that it would spin-off its steel business in 2014.

Going Forward. This implicit or explicit alliance of activists and institutional investors can and will use the full arsenal of corporate governance tools to scrutinize boards of directors. Where applicable, they will seek to influence board decisions or, when necessary, seek to change board composition.

Among the key steps boards need to take before an activist enters the landscape is shareholder engagement. Institutional shareholders should know that the board and management have a strategy to create shareholder value and are actively executing on that strategy. Ongoing engagement and relationship building with a company’s long-term shareholders can help the board establish the credibility it needs when the benefits of strategies are not realized as quickly or as completely as originally envisioned or other unforeseen circumstances damage corporate performance. Engagement also provides an important avenue for companies and boards to hear investor concerns and attempt to address them before they develop into problems that damage a board’s credibility or call into question the board’s composition or strategic decisions. Robust shareholder engagement has become, and will continue to be, an important part of the corporate governance landscape in 2014 and beyond.

*This article appeared in the firm's sixth annual edition of Insights on January 16, 2014.

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

© Skadden, Arps, Slate, Meagher & Flom LLP | Attorney Advertising

Written by:

Skadden, Arps, Slate, Meagher & Flom LLP

Skadden, Arps, Slate, Meagher & Flom LLP on:

Readers' Choice 2017
Reporters on Deadline

"My best business intelligence, in one easy email…"

Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra:
*By using the service, you signify your acceptance of JD Supra's Privacy Policy.
Custom Email Digest
- hide

JD Supra Privacy Policy

Updated: May 25, 2018:

JD Supra is a legal publishing service that connects experts and their content with broader audiences of professionals, journalists and associations.

This Privacy Policy describes how JD Supra, LLC ("JD Supra" or "we," "us," or "our") collects, uses and shares personal data collected from visitors to our website (located at www.jdsupra.com) (our "Website") who view only publicly-available content as well as subscribers to our services (such as our email digests or author tools)(our "Services"). By using our Website and registering for one of our Services, you are agreeing to the terms of this Privacy Policy.

Please note that if you subscribe to one of our Services, you can make choices about how we collect, use and share your information through our Privacy Center under the "My Account" dashboard (available if you are logged into your JD Supra account).

Collection of Information

Registration Information. When you register with JD Supra for our Website and Services, either as an author or as a subscriber, you will be asked to provide identifying information to create your JD Supra account ("Registration Data"), such as your:

  • Email
  • First Name
  • Last Name
  • Company Name
  • Company Industry
  • Title
  • Country

Other Information: We also collect other information you may voluntarily provide. This may include content you provide for publication. We may also receive your communications with others through our Website and Services (such as contacting an author through our Website) or communications directly with us (such as through email, feedback or other forms or social media). If you are a subscribed user, we will also collect your user preferences, such as the types of articles you would like to read.

Information from third parties (such as, from your employer or LinkedIn): We may also receive information about you from third party sources. For example, your employer may provide your information to us, such as in connection with an article submitted by your employer for publication. If you choose to use LinkedIn to subscribe to our Website and Services, we also collect information related to your LinkedIn account and profile.

Your interactions with our Website and Services: As is true of most websites, we gather certain information automatically. This information includes IP addresses, browser type, Internet service provider (ISP), referring/exit pages, operating system, date/time stamp and clickstream data. We use this information to analyze trends, to administer the Website and our Services, to improve the content and performance of our Website and Services, and to track users' movements around the site. We may also link this automatically-collected data to personal information, for example, to inform authors about who has read their articles. Some of this data is collected through information sent by your web browser. We also use cookies and other tracking technologies to collect this information. To learn more about cookies and other tracking technologies that JD Supra may use on our Website and Services please see our "Cookies Guide" page.

How do we use this information?

We use the information and data we collect principally in order to provide our Website and Services. More specifically, we may use your personal information to:

  • Operate our Website and Services and publish content;
  • Distribute content to you in accordance with your preferences as well as to provide other notifications to you (for example, updates about our policies and terms);
  • Measure readership and usage of the Website and Services;
  • Communicate with you regarding your questions and requests;
  • Authenticate users and to provide for the safety and security of our Website and Services;
  • Conduct research and similar activities to improve our Website and Services; and
  • Comply with our legal and regulatory responsibilities and to enforce our rights.

How is your information shared?

  • Content and other public information (such as an author profile) is shared on our Website and Services, including via email digests and social media feeds, and is accessible to the general public.
  • If you choose to use our Website and Services to communicate directly with a company or individual, such communication may be shared accordingly.
  • Readership information is provided to publishing law firms and authors of content to give them insight into their readership and to help them to improve their content.
  • Our Website may offer you the opportunity to share information through our Website, such as through Facebook's "Like" or Twitter's "Tweet" button. We offer this functionality to help generate interest in our Website and content and to permit you to recommend content to your contacts. You should be aware that sharing through such functionality may result in information being collected by the applicable social media network and possibly being made publicly available (for example, through a search engine). Any such information collection would be subject to such third party social media network's privacy policy.
  • Your information may also be shared to parties who support our business, such as professional advisors as well as web-hosting providers, analytics providers and other information technology providers.
  • Any court, governmental authority, law enforcement agency or other third party where we believe disclosure is necessary to comply with a legal or regulatory obligation, or otherwise to protect our rights, the rights of any third party or individuals' personal safety, or to detect, prevent, or otherwise address fraud, security or safety issues.
  • To our affiliated entities and in connection with the sale, assignment or other transfer of our company or our business.

How We Protect Your Information

JD Supra takes reasonable and appropriate precautions to insure that user information is protected from loss, misuse and unauthorized access, disclosure, alteration and destruction. We restrict access to user information to those individuals who reasonably need access to perform their job functions, such as our third party email service, customer service personnel and technical staff. You should keep in mind that no Internet transmission is ever 100% secure or error-free. Where you use log-in credentials (usernames, passwords) on our Website, please remember that it is your responsibility to safeguard them. If you believe that your log-in credentials have been compromised, please contact us at privacy@jdsupra.com.

Children's Information

Our Website and Services are not directed at children under the age of 16 and we do not knowingly collect personal information from children under the age of 16 through our Website and/or Services. If you have reason to believe that a child under the age of 16 has provided personal information to us, please contact us, and we will endeavor to delete that information from our databases.

Links to Other Websites

Our Website and Services may contain links to other websites. The operators of such other websites may collect information about you, including through cookies or other technologies. If you are using our Website or Services and click a link to another site, you will leave our Website and this Policy will not apply to your use of and activity on those other sites. We encourage you to read the legal notices posted on those sites, including their privacy policies. We are not responsible for the data collection and use practices of such other sites. This Policy applies solely to the information collected in connection with your use of our Website and Services and does not apply to any practices conducted offline or in connection with any other websites.

Information for EU and Swiss Residents

JD Supra's principal place of business is in the United States. By subscribing to our website, you expressly consent to your information being processed in the United States.

  • Our Legal Basis for Processing: Generally, we rely on our legitimate interests in order to process your personal information. For example, we rely on this legal ground if we use your personal information to manage your Registration Data and administer our relationship with you; to deliver our Website and Services; understand and improve our Website and Services; report reader analytics to our authors; to personalize your experience on our Website and Services; and where necessary to protect or defend our or another's rights or property, or to detect, prevent, or otherwise address fraud, security, safety or privacy issues. Please see Article 6(1)(f) of the E.U. General Data Protection Regulation ("GDPR") In addition, there may be other situations where other grounds for processing may exist, such as where processing is a result of legal requirements (GDPR Article 6(1)(c)) or for reasons of public interest (GDPR Article 6(1)(e)). Please see the "Your Rights" section of this Privacy Policy immediately below for more information about how you may request that we limit or refrain from processing your personal information.
  • Your Rights
    • Right of Access/Portability: You can ask to review details about the information we hold about you and how that information has been used and disclosed. Note that we may request to verify your identification before fulfilling your request. You can also request that your personal information is provided to you in a commonly used electronic format so that you can share it with other organizations.
    • Right to Correct Information: You may ask that we make corrections to any information we hold, if you believe such correction to be necessary.
    • Right to Restrict Our Processing or Erasure of Information: You also have the right in certain circumstances to ask us to restrict processing of your personal information or to erase your personal information. Where you have consented to our use of your personal information, you can withdraw your consent at any time.

You can make a request to exercise any of these rights by emailing us at privacy@jdsupra.com or by writing to us at:

Privacy Officer
JD Supra, LLC
10 Liberty Ship Way, Suite 300
Sausalito, California 94965

You can also manage your profile and subscriptions through our Privacy Center under the "My Account" dashboard.

We will make all practical efforts to respect your wishes. There may be times, however, where we are not able to fulfill your request, for example, if applicable law prohibits our compliance. Please note that JD Supra does not use "automatic decision making" or "profiling" as those terms are defined in the GDPR.

  • Timeframe for retaining your personal information: We will retain your personal information in a form that identifies you only for as long as it serves the purpose(s) for which it was initially collected as stated in this Privacy Policy, or subsequently authorized. We may continue processing your personal information for longer periods, but only for the time and to the extent such processing reasonably serves the purposes of archiving in the public interest, journalism, literature and art, scientific or historical research and statistical analysis, and subject to the protection of this Privacy Policy. For example, if you are an author, your personal information may continue to be published in connection with your article indefinitely. When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
  • Onward Transfer to Third Parties: As noted in the "How We Share Your Data" Section above, JD Supra may share your information with third parties. When JD Supra discloses your personal information to third parties, we have ensured that such third parties have either certified under the EU-U.S. or Swiss Privacy Shield Framework and will process all personal data received from EU member states/Switzerland in reliance on the applicable Privacy Shield Framework or that they have been subjected to strict contractual provisions in their contract with us to guarantee an adequate level of data protection for your data.

California Privacy Rights

Pursuant to Section 1798.83 of the California Civil Code, our customers who are California residents have the right to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes.

You can make a request for this information by emailing us at privacy@jdsupra.com or by writing to us at:

Privacy Officer
JD Supra, LLC
10 Liberty Ship Way, Suite 300
Sausalito, California 94965

Some browsers have incorporated a Do Not Track (DNT) feature. These features, when turned on, send a signal that you prefer that the website you are visiting not collect and use data regarding your online searching and browsing activities. As there is not yet a common understanding on how to interpret the DNT signal, we currently do not respond to DNT signals on our site.

Access/Correct/Update/Delete Personal Information

For non-EU/Swiss residents, if you would like to know what personal information we have about you, you can send an e-mail to privacy@jdsupra.com. We will be in contact with you (by mail or otherwise) to verify your identity and provide you the information you request. We will respond within 30 days to your request for access to your personal information. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why. If you would like to correct or update your personal information, you can manage your profile and subscriptions through our Privacy Center under the "My Account" dashboard. If you would like to delete your account or remove your information from our Website and Services, send an e-mail to privacy@jdsupra.com.

Changes in Our Privacy Policy

We reserve the right to change this Privacy Policy at any time. Please refer to the date at the top of this page to determine when this Policy was last revised. Any changes to our Privacy Policy will become effective upon posting of the revised policy on the Website. By continuing to use our Website and Services following such changes, you will be deemed to have agreed to such changes.

Contacting JD Supra

If you have any questions about this Privacy Policy, the practices of this site, your dealings with our Website or Services, or if you would like to change any of the information you have provided to us, please contact us at: privacy@jdsupra.com.

JD Supra Cookie Guide

As with many websites, JD Supra's website (located at www.jdsupra.com) (our "Website") and our services (such as our email article digests)(our "Services") use a standard technology called a "cookie" and other similar technologies (such as, pixels and web beacons), which are small data files that are transferred to your computer when you use our Website and Services. These technologies automatically identify your browser whenever you interact with our Website and Services.

How We Use Cookies and Other Tracking Technologies

We use cookies and other tracking technologies to:

  1. Improve the user experience on our Website and Services;
  2. Store the authorization token that users receive when they login to the private areas of our Website. This token is specific to a user's login session and requires a valid username and password to obtain. It is required to access the user's profile information, subscriptions, and analytics;
  3. Track anonymous site usage; and
  4. Permit connectivity with social media networks to permit content sharing.

There are different types of cookies and other technologies used our Website, notably:

  • "Session cookies" - These cookies only last as long as your online session, and disappear from your computer or device when you close your browser (like Internet Explorer, Google Chrome or Safari).
  • "Persistent cookies" - These cookies stay on your computer or device after your browser has been closed and last for a time specified in the cookie. We use persistent cookies when we need to know who you are for more than one browsing session. For example, we use them to remember your preferences for the next time you visit.
  • "Web Beacons/Pixels" - Some of our web pages and emails may also contain small electronic images known as web beacons, clear GIFs or single-pixel GIFs. These images are placed on a web page or email and typically work in conjunction with cookies to collect data. We use these images to identify our users and user behavior, such as counting the number of users who have visited a web page or acted upon one of our email digests.

JD Supra Cookies. We place our own cookies on your computer to track certain information about you while you are using our Website and Services. For example, we place a session cookie on your computer each time you visit our Website. We use these cookies to allow you to log-in to your subscriber account. In addition, through these cookies we are able to collect information about how you use the Website, including what browser you may be using, your IP address, and the URL address you came from upon visiting our Website and the URL you next visit (even if those URLs are not on our Website). We also utilize email web beacons to monitor whether our emails are being delivered and read. We also use these tools to help deliver reader analytics to our authors to give them insight into their readership and help them to improve their content, so that it is most useful for our users.

Analytics/Performance Cookies. JD Supra also uses the following analytic tools to help us analyze the performance of our Website and Services as well as how visitors use our Website and Services:

  • HubSpot - For more information about HubSpot cookies, please visit legal.hubspot.com/privacy-policy.
  • New Relic - For more information on New Relic cookies, please visit www.newrelic.com/privacy.
  • Google Analytics - For more information on Google Analytics cookies, visit www.google.com/policies. To opt-out of being tracked by Google Analytics across all websites visit http://tools.google.com/dlpage/gaoptout. This will allow you to download and install a Google Analytics cookie-free web browser.

Facebook, Twitter and other Social Network Cookies. Our content pages allow you to share content appearing on our Website and Services to your social media accounts through the "Like," "Tweet," or similar buttons displayed on such pages. To accomplish this Service, we embed code that such third party social networks provide and that we do not control. These buttons know that you are logged in to your social network account and therefore such social networks could also know that you are viewing the JD Supra Website.

Controlling and Deleting Cookies

If you would like to change how a browser uses cookies, including blocking or deleting cookies from the JD Supra Website and Services you can do so by changing the settings in your web browser. To control cookies, most browsers allow you to either accept or reject all cookies, only accept certain types of cookies, or prompt you every time a site wishes to save a cookie. It's also easy to delete cookies that are already saved on your device by a browser.

The processes for controlling and deleting cookies vary depending on which browser you use. To find out how to do so with a particular browser, you can use your browser's "Help" function or alternatively, you can visit http://www.aboutcookies.org which explains, step-by-step, how to control and delete cookies in most browsers.

Updates to This Policy

We may update this cookie policy and our Privacy Policy from time-to-time, particularly as technology changes. You can always check this page for the latest version. We may also notify you of changes to our privacy policy by email.

Contacting JD Supra

If you have any questions about how we use cookies and other tracking technologies, please contact us at: privacy@jdsupra.com.

- hide

This website uses cookies to improve user experience, track anonymous site usage, store authorization tokens and permit sharing on social media networks. By continuing to browse this website you accept the use of cookies. Click here to read more about how we use cookies.