Shareholder Proposal No-Action Requests in the 2023 Proxy Season
Harvard Corporate Governance
JULY 8, 2023
Posted by Marc S. Gerber and Ryan J. Adams, Skadden, Arps, Slate, Meagher & Flom LLP, on Saturday, July 8, 2023 Editor's Note: Marc S. Gerber is a Partner and Ryan J. Adams is Counsel at Skadden, Arps, Slate, Meagher & Flom LLP. This post is based on their Skadden memorandum. Key Points Companies lodged fewer no-action requests for the exclusion of shareholder proposals in the 2023 proxy season after the SEC Staff outlined new guidelines in 2021 and the Staff rejected many requests in th
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