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Courtesy of Proxy Analytics, notable no-action letter developments and voting for the 2024 season for the two weeks ended March 8 include the following:

• Of eight of the nine no-action requests granted by the SEC last week under Rule 14a-8(i)(7), seemingly consistent with a 2024 season trend, five were granted under the micromanagement exception rather than the ordinary business exception. While grants under the micromanagement exception comprised between 11% and 27% of all Rule 14a-8(i)(7) requests in the past three proxy seasons, they are nearing 50% this season to date.
• Micromanagement-based no-action relief was used last week in relation to proposals on a living wage, climate-related financing (here, here, and here), and director time commitments, and the week prior in relation to a proposal seeking a board report on the benefits and drawbacks of permanently committing to not engage in titanium mining or purchase titanium mined by others on the Okefenokee’s hydrologic boundary and an assessment of related risks (consistent with disposition of a similar proposal the week prior, which we reported on here).
• Relief was granted this past week under Rule 14a-8(i)(7)’s ordinary business exception for a “healthy products” proposal.
• One climate-related proposal (p73) requesting disclosure of Scope 1 and 2 GHG emissions, short-, medium- and long-term goals for reducing emissions, and an annual progress report, garnered majority (57%) shareholder support, making it the first E&S majority-supported proposal this season.

Access additional resources on our Proxy & Annual Reporting Season 2024 page.

                       This post first appeared in the weekly Society Alert!