Yearly Archives: 2021

Weekly Roundup: June 25–July 1, 2021


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This roundup contains a collection of the posts published on the Forum during the week of June 25–July 1, 2021.


The Board Diversity Census of Women and Minorities on Fortune 500 Boards


A New Angle on Cybersecurity Enforcement from the SEC


Phantom of the Opera: ETF Shorting and Shareholder Voting


How Companies Should Respond to the SEC’s Enhanced Focus on Rule 10b5-1 Plans


Tone at the Bottom: Measuring Corporate Misconduct Risk from the Text of Employee Reviews


Key Corporate Governance Issues at Mid-Year 2021



What Does Codetermination Do?



Measuring Up To HCM


How Do Asset Managers Create Subsidies for Certain Firms?


Keynote Address by Commissioner Lee on Climate, ESG, and the Board of Directors



ESG & Long-Term Disclosures: The State of Play in Biopharma


Rights Offers and Delaware Law

Jesse M. Fried is Dane Professor of Law at Harvard Law School. This post is based on his recent paper, and is part of the Delaware law series; links to other posts in the series are available here.

Under Delaware law, a securities issuance by a public or private firm in which all investors may participate pro rata (a “rights offer”) is generally seen as treating corporate insiders and existing outside investors alike. This view makes it difficult for nonparticipating outsiders to prevail on a “cheap-issuance” claim: that the insiders sold themselves cheap securities via the rights offer.

In a paper recently posted on SSRN, Rights Offers and Delaware Law, I explain how insiders can use rights offers to sell themselves cheap securities at outsiders’ expense, and suggest how courts applying Delaware law should probe the fairness of rights offers.

Under Delaware law, any transaction (including a securities issuance) allegedly benefitting insiders at outsiders’ expense can give rise to “entire fairness” review, under which insiders must prove that both price and process were fair. However, by structuring an issuance as a rights offer, which appears to protect outsiders, insiders have gained substantial legal insulation from outsiders’ claims. Certain cases (e.g., WatchMark v. ARGO (Del. Ch. 2004)) suggest that the use of a rights offer could lead to review under the much more lenient business judgment rule. When a rights offer is followed by a merger, other cases (e.g., Feldman v. Cutaia (Del. Ch. 2007)) suggest that insiders may well be able to avoid any judicial review whatsoever. And, even if fairness review cannot be avoided, the use of a rights offer may well go far to help satisfy entire fairness.

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ESG & Long-Term Disclosures: The State of Play in Biopharma

Anuj A. Shah is Partner and Head of US & UK at KKS Advisors; Brian Tomlinson is Director of Research at the CEO Investor Forum, Chief Executives for Corporate Purpose (CECP); Emilie Kehl is Senior Associate and Lukas Rossi is an Associate at KKS Advisors. This post is based on their recent paper. Related research from the Program on Corporate Governance includes The Illusory Promise of Stakeholder Governance by Lucian A. Bebchuk and Roberto Tallarita (discussed on the Forum here); For Whom Corporate Leaders Bargain by Lucian A. Bebchuk, Kobi Kastiel, and Roberto Tallarita (discussed on the Forum here); Socially Responsible Firms by Alan Ferrell, Hao Liang, and Luc Renneboog (discussed on the Forum here); and Restoration: The Role Stakeholder Governance Must Play in Recreating a Fair and Sustainable American Economy—A Reply to Professor Rock by Leo E. Strine, Jr. (discussed on the Forum here).

Executive Summary

How much forward-looking information do public companies disclose, including on ESG themes? Do they provide targets and KPIs on themes key to long-term value creation? In this paper, we analyze the accessibility, quantity, and time frame of forward-looking information disclosed by the 25 constituents in the S&P 500 Pharmaceuticals, Biotechnology & Life Sciences GICS industry classifications.

Using an updated version of CECP’s Long-Term Plan (“LTP”) Framework, we assess four key disclosure channels (annual reports/10-K, stand-alone sustainability reports, proxy statements, and investor day transcripts) and find that forward-looking information is dispersed, and locating it is complex and time-consuming.

In addition, the amount of forward-looking disclosure varies across the LTP Framework’s nine themes, with the most found across the themes of Competitive Positioning and Trends. We find that near-term disclosures are most common.

We conclude with a practical set of executive-ready recommendations for corporate managers focused on setting targets, increasing transparency, refreshing materiality, and providing commentary on ESG disclosures.

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Tech Companies Come Together on Climate-Related Disclosures

Melissa Pfeuffer is Capital Markets Business Development Practice Group Specialist at Mayer Brown LLP. This post is based on her Mayer Brown memorandum.

In a comment letter to the Securities and Exchange Commission on June 11, seven well-known tech companies responded to SEC Acting Chair Allison Herren Lee’s March 2021 request for public input on climate change disclosures (see our related blog post). The letter expressed support for consistent reporting by public companies regarding climate-related matters.

With acknowledgement regarding the severity and urgency of addressing climate change issues, the letter mentions that the companies believe “…it is critical to regularly measure and report on progress towards climate commitments.” The letter notes the importance of sharing updates with investors and stakeholders, stating, “Investors need clear, comprehensive, high-quality information on the impacts of climate change for market participants.”

The letter addressed to Chair Gensler specifically outlined some climate disclosure suggestions for the SEC to consider, including:

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Keynote Address by Commissioner Lee on Climate, ESG, and the Board of Directors

Allison Herren Lee is a Commissioner at the U.S. Securities and Exchange Commission. This post is based on her recent Keynote Address at the 2021 Society for Corporate Governance National Conference. The views expressed in the post are those of Commissioner Lee, and do not necessarily reflect those of the Securities and Exchange Commission or the Staff.

“You Cannot Direct the Wind, But You Can Adjust Your Sails” [1]

Good morning and thank you for the invitation to speak today at the Society for Corporate Governance 2021 National Conference. I’m impressed with your full and informative agenda over the next few days, and I appreciate the important work you do in supporting company boards and executives.

I also appreciate your engagement in the SEC’s policymaking process, including your recent letter in response to the request for public input on climate change disclosures. In fact, we’ve received thousands of comments in response to that request, but we hardly need that statistic to understand that the subject of climate risk and our financial markets, and ESG more broadly, is top of mind in board rooms and c-suites around the globe.

Increasingly, boards of directors are called upon to navigate the challenges presented by climate change, racial injustice, economic inequality, and numerous other issues that are fundamental to the success and sustainability of companies, financial markets, and our economy. This call, welcomed by some and eschewed by others, is attributable in part to the large and growing influence that corporations hold over the social and economic well-being of people and communities everywhere. A study from 2018, for example, showed that 71 of the top 100 revenue generators globally were corporations while only 29 were countries. [2] In other words, corporations—in many cases U.S. corporations—often operate on a level or higher economic footing than some of the largest governments in the world. That is a dynamic worthy of reflection—and one that drives home the weighty consequences and obligations associated with some corporate decisions.

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How Do Asset Managers Create Subsidies for Certain Firms?

Anil K. Kashyap is Stevens Distinguished Service Professor of Economics and Finance at the University of Chicago; Natalia Kovrijnykh is Associate Professor of Economics at Arizona State University; Jian Li is Assistant Professor of Finance at Columbia Business School; and Anna Pavlova is Professor of Finance at London Business School. This post is based on their recent paper.

Since the 1980s economists have known that when stocks are added to the S&P 500 index their prices rise. There are now many theories that aim to explain this fact. Yet almost all of the related research has focused on how indices influence asset prices, with much less attention paid to other possible implications. In The Benchmark Inclusion Subsidy, we look at the repercussions of index inclusion for corporate decisions.

Asset management practices affect corporate decisions

Most fund managers’ performance is judged against benchmarks. Because the asset management industry is estimated to control more than $100 trillion worldwide, this means that there is a huge pool of money where the people making investment decisions have strong incentives to favor buying stocks inside the index instead ones that are outside it. We construct a model to analyse the consequences of these incentives.

The model predicts that firms that are part of a benchmark have a different cost of capital than similar firms outside the benchmark. When a firm adds risky cash flows, say, because of an acquisition or by investing in a new project, the increase in the shareholder value is larger if the firm is inside the benchmark. Hence, a firm in the benchmark could accept a project that an otherwise identical non-benchmark firm would not. This runs contrary to standard corporate finance theory. In the special case where there are no fund managers—as is standard in corporate finance—investors always value equivalent cash flows of benchmark and non-benchmark firms in the same way.

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Measuring Up To HCM

Avi Sheldon is a consultant at Semler Brossy. This post is based on his Semler Brossy memorandum.

Corporate sustainability risks and opportunities have received increasing interest from investors for the past decade.

Environmental concerns initially led the list, but attention to human capital has swiftly emerged as an additional focal point of discussion in the boardroom. Investors and other stakeholders are prodding companies to reveal more about their human capital practices and metrics. Boards are now scrambling to refine and articulate their strategies and investments in this area.

Human capital management (HCM) can be thought of as how an organisation strategically operates and invests in its workforce, with an eye towards optimising long-term value creation. It recognises human capital as a critical asset and modernises the understanding of HR departments as strategy and profit centres, not just cost centres.

HCM is therefore a sustainability topic that many stakeholders request more information about. How and why has a company invested in its workforce? Is there underinvestment that presents long-term risk? With HCM disclosure increasingly within investor crosshairs, many US corporations are bucking tradition by detailing elements of their HCM within the proxy statement.

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Comments to the Proposed Amendments to Require the Use of Universal Proxies

Steve Wolosky is partner at Olshan Frome Wolosky LLP. This post is based on his comment letter to the U.S. Securities and Exchange Commission. Related research from the Program on Corporate Governance includes Universal Proxies by Scott Hirst (discussed on the Forum here).

Olshan Frome Wolosky LLP (“Olshan”) is pleased to submit its comments to the proposed amendments to the federal proxy rules to require the use of universal proxies in non-exempt solicitations in connection with contested elections of directors as described in Release No. 34-79164 published by the Securities and Exchange Commission (“SEC”) on October 26, 2016. We commend the Staff for reopening the comment period pursuant to Release No. 34-91603 (the “Release”) given the passage of time since the initial comment period and continued interest and discourse among market participants on this topic.

Olshan’s Shareholder Activism Practice Group is widely recognized as the nation’s premier legal practice in representing activist investors in contested solicitations. We have vast experience counseling clients on a wide variety of activist strategies, from election contests, consent solicitations and hostile takeovers to letter writing campaigns and behind-the-scenes discussions with management and boards of directors. We are consistently ranked as the leading legal advisor to activist investors by various publications that cover shareholder activism, including Activist Insight Monthly, The Deal Activism League Table, FactSet SharkRepellent, The Legal 500 United States Guide, Bloomberg Activism Advisory League Table and Refinitiv Global Shareholder Activism Scorecard. In 2020, our firm advised on 111 activist campaigns, or 74 more campaigns than our next closest competitor, according to Bloomberg’s Activism Advisory League Tables. We believe our position as the leading law firm in the shareholder activism arena gives us unique insight and perspective into the proxy process and the proposed legal, procedural and policy considerations underlying the universal proxy rule proposal.

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What Does Codetermination Do?

Simon Jäger is the Silverman (1968) Family Career Development Assistant Professor of Economics at the Massachusetts Institute of Technology; Shakked Noy is a Predoctoral Research Fellow at the Massachusetts Institute of Technology; and Benjamin Schoefer is Assistant Professor of Economics at the University of California, Berkeley. This post is based on their recent paper. Related research from the Program on Corporate Governance includes The Illusory Promise of Stakeholder Governance by Lucian A. Bebchuk and Roberto Tallarita (discussed on the Forum here); For Whom Corporate Leaders Bargain by Lucian A. Bebchuk, Kobi Kastiel, and Roberto Tallarita (discussed on the Forum here); and Restoration: The Role Stakeholder Governance Must Play in Recreating a Fair and Sustainable American Economy—A Reply to Professor Rock by Leo E. Strine, Jr. (discussed on the Forum here).

In liberal market economies such as the United States, firms are controlled ultimately by their shareholders or owners, and (under the dominant legal doctrine of “shareholder primacy”) are governed with the exclusive purpose of maximizing the welfare of those shareholders and owners. By contrast, large firms in many European countries are jointly governed by their shareholders and workers, through “codetermination” arrangements mandated by law. Under “board-level” codetermination, workers elect representatives who fill a certain share (usually 20-40%) of the seats on their company’s board. Under “shop-floor” codetermination, workers elect shop-floor representatives who have rights to information, consultation, and sometimes co-decision-making over decisions about working conditions. Recent legislative proposals in the United States, including the Reward Work Act and Accountable Capitalism Act, and recent campaign proposals in the United Kingdom and Australia, would introduce board-level codetermination requirements for large firms in those countries. In addition, the possibility of amending the National Labor Relations Act to allow for experimentation with shop-floor codetermination in the US has been raised repeatedly in recent years (Liebman, 2017; Andrias and Rogers, 2018; Block, 2018).

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Alarm.com and the Open Questions Regarding Trade Secret Claims Related To Usurpation of Corporate Opportunities

Robert S. Velevis is partner and Lora Chowdhury is an associate at Sidley Austin LLP. This post is based on their Sidley memorandum, and is part of the Delaware law series; links to other posts in the series are available here.

In a previous memorandum, we discussed a recent Texas Court of Appeals case which held that members of a Delaware LLC can contract around (i.e., waive) the general principle protecting against usurpation of corporate opportunities. See Patterson v. Five Point Midstream Funds I and II, L.P., Case No. 01-19-00-643-CV (Tex. App. Dec. 8, 2020). We discussed that the Patterson decision followed a trend in Delaware that permits parties to contract around the traditional rules prohibiting usurpation of corporate opportunities. See Alarm.com Holdings, Inc. v. ABS Capital Partners Inc., No. CV 2017-0583-JTL, 2018 WL 3006118 (Del. Ch. June 15, 2018), aff’d, 204 A.3d 113 (Del. 2019). In December 2019, the Delaware Supreme Court in Alarm.com, affirmed a decision penned by Vice Chancellor Laster out of the Court of Chancery dismissing a claim under the Delaware Uniform Trade Secret Act (DUTSA).

In this post, we will take a deeper dive into Alarm.com, the open questions it left, and potential new developments to keep an eye out for concerning waiver of usurpation of corporate opportunities in the private equity realm. This decision — and the open questions that have not yet been addressed by subsequent cases — is of particular importance to private equity owners that hold investment in companies governed by Delaware law.

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