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Shareholder Rights

Vinson & Elkins LLP

No Action for No-Actions: SEC Announces Significant Change in No-Action Relief During the 2025-26 Proxy Season

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On November 17, 2025, the Division of Corporation Finance (the “Division”) of the Securities and Exchange Commission (the “SEC”) announced it will not respond to, and will express no views on, requests for exclusions of...more

Keating Muething & Klekamp PLL

Proxy Season Update: SEC will not respond to Most Shareholder Proposal No-action Requests

On November 17, 2025, the SEC’s Division of Corporation Finance issued a statement regarding no action letter requests related to Rule 14a-8 shareholder proposals....more

Seward & Kissel LLP

The SEC Puts Precatory Proposals on the Chopping Block

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The SEC Chairman indicates a policy shift for public companies, inviting them to take action to exclude precatory shareholder proposals from their proxy materials. In a recent keynote address at the Weinberg Center for...more

Cooley LLP

Vanguard Adds $1.4 Trillion in Funds to Its Voting Choice Program

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We’ve been blogging quite a bit about ExxonMobil’s retail voting program, including this blog about a recent lawsuit filed against it. It remains to be seen whether other companies will pursue this type of program even though...more

Herbert Smith Freehills Kramer

Whose Deal is It Anyway? ASX Consults on Shareholder Approvals for Offering Bidder Scrip in M&A

In brief - On 20 October 2025, ASX released its consultation paper titled “Shareholder approval of dilutive acquisitions and changes in admission status” (Consultation Paper) (link to the Consultation Paper here)....more

Wilson Sonsini Goodrich & Rosati

Navigating Shareholder Engagement and Shareholder Activism: Essentials and Best Practices

Engaging with shareholders and responding to shareholder activism continue to be top-of-mind for public companies. These situations present opportunities for management teams and boards of directors to work together to...more

Ropes & Gray LLP

SEC Staff Clears the Way for Standing Proxies under Retail Shareholder Voting Program

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On September 15, 2025, the staff of the U.S. Securities and Exchange Commission (the “SEC”) granted no-action relief with respect to the compliance of Exxon’s proposed retail shareholder voting program (the “program”) with...more

Latham & Watkins LLP

Italian Council of Ministers Approves in a Preliminary Review the Legislative Decree Modifying the Consolidated Financial Act

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The Legislative Decree introduces significant changes with regard to takeover bids, corporate governance, and other obligations for listed companies....more

Cooley LLP

Will Lack of Shareholder Proposals Mean More ‘Vote No’ Campaigns? Maybe It Already Has…

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I’ve blogged a few times about how the SEC Chairman Paul Atkins has delivered a speech in which he stated that one of his top priorities is to make being a public company an attractive proposition, with eliminating precatory...more

Vinson & Elkins LLP

When Should Boards Fight (and Not Settle)?

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In the headlines today, it is common to see announcements about activist campaigns or activists taking equity positions in public companies. Nonetheless, full-scale proxy fights have become relatively rare. Most public...more

Cooley LLP

How Do You Know Which Issues to Engage On?

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The initial obvious answer is to engage on issues that the investors you’re meeting want to talk about. That’s the primary purpose of engagement – to find out what investors want to know and give them that information....more

Eversheds Sutherland (US) LLP

Green light for retail voting program: SEC issues no-action relief for ExxonMobil’s retail voting program

On September 15, 2025, the SEC’s Division of Corporation Finance issued no-action relief to ExxonMobil (Exxon) regarding the company’s retail voting program in response to a request letter submitted by Exxon to the SEC on the...more

Cooley LLP

Activism in 2025 and Beyond: Universal Proxy, Litigation Leverage and a New Playbook for Preparedness

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Activism didn’t pause in 2025 – it evolved. Campaign counts are up, tactics have multiplied, and boards are settling faster and earlier. As Goldman Sachs’ Neil Rudisill put it on Cooley’s Market Talks panel, “We’re on...more

Cooley LLP

Crocodile Tears for Retail Investors: The Misleading Campaign Against Retail Voting Programs

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On September 15, the Securities and Exchange Commission (SEC) Office of Mergers and Acquisitions responded to a no-action request from Exxon Mobil Corporation (Exxon), confirming that it would not recommend enforcement action...more

A&O Shearman

"Capable of Remedy" - Putting the Genie Back Into the Bottle

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In Kulkarni v Gwent, the Court of Appeal found that “material” and “persistent” breaches of a shareholders' agreement could be remedied, even though they were grounds for terminating the contract....more

Herbert Smith Freehills Kramer

On-market Purchases by a Bidder - More From the Takeovers Panel

On-market acquisitions by a bidder at prices higher than the announced bid price are not inherently illegal or unacceptable, but they should be announced promptly. ...more

Latham & Watkins LLP

SEC Staff Grants No-Action Relief Allowing Retail Investors to Give Standing Voting Instructions

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The SEC Staff issued a no-action letter to Exxon Mobil Corporation on September 15, 2025, confirming that it would not recommend enforcement action under the proxy rules if the company implements a first-of-its-kind system...more

Cooley LLP

Governance on the IPO Path: Nine Tips for Late-Stage Private Companies

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In today’s market, an initial public offering (IPO) can be an attractive liquidity option – but you have to be ready to price when the moment is right. While the business and management story, financial reporting and...more

BCLP

Divided SEC Clears Way for Mandatory Arbitration Clauses in Company Governance Documents

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On September 17, 2025, without seeking public comment, the SEC approved two controversial items in a 3-1 vote...more

Walkers

Anti-takeover protections employed by listed Cayman Islands companies

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Cayman company structures give boards flexibility to adopt anti-takeover measures. Anti-takeover devices remain a core advantage for Cayman companies listed on global markets....more

Skadden, Arps, Slate, Meagher & Flom LLP

Activists Say ‘Yes’ to ‘Vote No’ Campaigns in 2025

Withhold campaigns are not new. However, according to Diligent Market Intelligence, 33 distinct activist withhold campaigns took place in the 12 months ended June 30, 2025, up from 23 in the same period of 2023–24 and 24...more

White & Case LLP

Summary of June 2025 Annual General Shareholder Meeting Season Shareholder Proposals

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According to the news reports, during the June 2025 annual general meeting season, shareholders made a total of 399 proposals to 114 Japanese publicly listed companies. This marks the fourth consecutive year of...more

Jackson Walker

New Texas Law Applicable to “Nationally Listed Corporations” Sets Forth Heightened Requirements for Shareholder Proposals

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Texas Senate Bill 1057, which became effective September 1, 2025, adds new Section 21.373 to the Texas Business Organizations Code (“TBOC”). This new Section of the TBOC creates a framework that governs when and how...more

Paul Hastings LLP

Reincorporating in Nevada: Considerations for Public Companies

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After decades of dominance by Delaware, there is a renewed competition for corporate charters among states. Nevada, Texas and several others are making efforts to attract companies to initially organize or reincorporate in...more

Pillsbury - Propel

Who’s Actually in Charge Here?: The Real Difference Between Shareholders, Directors and Officers (and Why It Matters to Founders)

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When you’re launching a startup, it’s easy to blur the lines between owners, decision-makers and doers—especially when you’re all three. But as soon as you raise money, add a co-founder, or bring on outside help, things get...more

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