Monthly Archives: January 2023

Cross-Border M&A – 2023 Checklist for Successful Acquisitions in the U.S.

Adam O. Emmerich and Robin Panovka are Partners at Wachtell, Lipton, Rosen & Katz. This post is based on a Wachtell Lipton memorandum by Mr. Emmerich, Mr. Panovka, Jodi J. SchwartzDavid A. KatzIlene Knable Gotts, Andrew J. Nussbaum and colleagues at Wachtell Lipton. Related research from the Program on Corporate Governance includes Are M&A Contract Clauses Value Relevant to Target and Bidder Shareholders? (discussed on the Forum here) by John C. Coates, Darius Palia, and Ge Wu; and The New Look of Deal Protection (discussed on the Forum here) by Fernan Restrepo and Guhan Subramanian. 

After a record-shattering year for M&A in 2021, a crescendo that built over a decade, powered by unique pandemic conditions, 2022 was, statistically, a reversion to the mean. Worldwide M&A volume was $3.6 trillion in 2022, as against $6.2 trillion in 2021 and an average of $4.3 trillion annually over the prior ten years (in 2022 dollars). Average, however, 2022 was anything but. Russia’s invasion of Ukraine sparked the largest armed conflict in Europe since World War II, creating a mass humanitarian crisis in Ukraine and the region, multiplying food and energy insecurity around the world, and exacerbating unresolved supply chain disruption caused by the coronavirus pandemic. Fiscal stimulus and adaptive monetary policies that supported growth during pandemic lockdowns were followed by inflation and hawkish policy responses, reversing a nearly 40-year trend of declining interest rates.

While M&A was not isolated from all of this upheaval, cross-border M&A continued to be attractive to dealmakers. Cross-border deals were 32% ($1.1 trillion) of global M&A in 2022, consistent with the average proportion over the prior ten years (35%). Acquisitions of U.S. companies by non-U.S. acquirors were $217 billion in transaction volume and represented 6% of 2022 global M&A volume and 19% of 2022 cross-border M&A volume. Canadian, British, Australian, Singaporean and Japanese acquirors accounted for 50% of the volume of cross border acquisitions of U.S. targets, while acquirors from China, India and other emerging economies accounted for about 8%.

We expect cross-border transactions into the U.S. to continue to offer compelling opportunities in 2023. Transacting parties will do better if they are well-prepared for the cultural, political, regulatory and technical complexity inherent in cross-border deals. Advance preparation, strategic implementation and deal structures calibrated to likely concerns are critically important. Now, more than ever, thoughtful regulatory strategy and creative financing approaches deserve special focus.

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D&O Insurers as ESG Monitors

Amelia Miazad is a Professor at the UC Davis School of Law. This post is based on her recent paper. Related research from the Program on Corporate Governance includes The Illusory Promise of Stakeholder Governance (discussed on the Forum here) and Will Corporations Deliver to All Stakeholders? (discussed on the Forum here) both by Lucian A. Bebchuk and Roberto Tallarita; Restoration: The Role Stakeholder Governance Must Play in Recreating a Fair and Sustainable American Economy—A Reply to Professor Rock (discussed on the Forum here) by Leo E. Strine, Jr; and Stakeholder Capitalism in the Time of Covid (discussed on the Forum here) by Lucian A. Bebchuk, Kobi Kastiel, and Roberto Tallarita.

Companies must reduce environmental and social harms to remain profitable over the long-term. In response to increasing investor and stakeholder demands, companies have ramped up their ESG commitments, from achieving “Net Zero” to closing the gender and racial pay gap. To protect investors and consumers from companies that make bold commitments, but lack the intention or ability to meet them, global regulators, including the SEC, are focused on “greenwashing”. At the same time, though, there is a proliferation of voluntary and mandatory ESG reporting obligations. And in March 2022, the SEC proposed rule amendments that would require public companies to disclose certain climate-related financial data. Notably, the SEC’s proposed rule encompasses disclosure of how boards are overseeing climate change risks.

Just as many corporate boards were beginning to align their risk oversight and decision-making with this new normal, an intensifying ESG backlash is complicating matters even more. A growing number of federal and state Republican lawmakers are directing  their ire at ESG and vowing to stop “elite progressives” from usurping “free markets”. Paradoxically, these free market champions are proposing–and enacting–sweeping legislation to constrain boards and investors from considering environmental and social risks.

As these discordant ESG demands play out in the public arena, board decision-making is more fraught with legal and regulatory risk than ever. We are already witnessing an increase in ESG-related shareholder litigation and SEC investigations. And a bevy of law firm memos warn that the proliferation of both pro and anti-ESG legislation increases legal risk for directors.

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2023 Annual Letter to Boards

Pamela Marcogliese is a Partner at Freshfields Bruckhaus Deringer LLP. This post is based on her Freshfields piece.

Introduction

Against a backdrop of challenging macroeconomic forces, our 2023 annual letter to boards is one that emphasizes understanding and preparing for the additional hurdles that will compound and be compounded by these macroeconomic forces.

How to Be Prepared for M&A Strategies in 2023

Regulators during 2023 will continue to use antitrust and foreign investment regimes to try to impede M&A strategies. Boards have to be prepared to resort to litigation, innovative fix-it-first strategies, and well-designed “efforts” covenants and “outside date” provisions to assure that the merger parties are aligned and prepared to survive the gauntlet of regulatory hurdles. In addition, understanding the interplay among the global regulators – especially the UK CMA, EC, China’s SAMR, and the US antitrust agencies, as well as CFIUS and the European, Asian and UK national security regulators – will be critical for boards to effectively evaluate risks and successfully execute their M&A projects.

We anticipate that it will be advisable for boards looking to divest businesses to continue to consider distributions of the business via a spin-off (including a Reverse Morris Trust), which allows for greater certainty of execution and an opportunity for a cash yield from leverage. A split-off, where the parent company offers shareholders the opportunity to exchange parent shares for SpinCo shares, achieves a similar outcome with the additional benefit of retiring parent shares and thereby enhancing EPS.

Many boards will have to become familiar in the coming months with the direct lending market, which is going to be the critical component for leveraged M&A in the near-term. Boards and management teams will need to understand how the process of obtaining commitments from direct lenders differs from, and in many ways is more burdensome than, the traditional approach of obtaining commitments from banks.

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Weekly Roundup: December 30-January 5, 2023


More from:

This roundup contains a collection of the posts published on the Forum during the week of December 30-January 5, 2023

SEC Press Release provides Compliance Checklist for Corporations


The Top 15 Anticipated ESG-Related Considerations That Will Influence Strategy in 2023


Crisis prevention and readiness



National Security Creep in Corporate Transactions


The board’s role: building trust in a multi-stakeholder world


ESMA Consultation Paper on Fund Names to Tackle Greenwashing


Industry Asset Revaluations around Public and Private Acquisitions


Activating Sustainability in the Boardroom


2022 U.S. CEO Outlook


Between Public and Private Enterprise: The Role and Structure of Special-Purpose Governments


2022 U.S. Shareholder Activism and Activist Settlement Agreements


2022 U.S. Shareholder Activism and Activist Settlement Agreements

Melissa Sawyer, Lauren Boehmke are partners and Susan M. Lindsay is counsel at Sullivan & Cromwell LLP. This post is based on a Sullivan & Cromwell memorandum by Ms. Sawyer, Ms. Boehmke, Ms. Lindsay, Rodge Cohen, and Marc Treviño. Related research from the Program on Corporate Governance includes Dancing with Activists (discussed on the Forum here) by Lucian A. Bebchuk, Alon Brav, Wei Jiang, and Thomas Keusch; The Long-Term Effects of Hedge Fund Activism (discussed on the Forum here) by Lucian A. Bebchuk, Alon Brav, and Wei Jiang; and Who Bleeds When the Wolves Bite? A Flesh-and-Blood Perspective on Hedge Fund Activism and Our Strange Corporate Governance System (discussed on the Forum here) by Leo E. Strine, Jr. 

TRENDS IN SHAREHOLDER ACTIVISM

A. ACTIVISM ACTIVITY SURGES DESPITE MACROECONOMIC UNCERTAINTY AND MARKET VOLATILITY, LEADING TO INCREASED USE OF RIGHTS PLANS

Activism activity surged in 2022 despite turbulent markets amid macroeconomic uncertainties, including the continuing impacts of COVID-19, rising inflation rates, global supply chain issues, higher oil prices and the Russia/Ukraine war. The first quarter of 2022 represented the busiest quarter for U.S. activism on record as company advance notice windows began opening for the 2022 annual meeting cycle, and activism activity levels remained elevated during the second and third quarters of 2022 as compared to 2021 and 2020 (though more in line with historic pre-pandemic levels). This is in contrast to 2020, when activism activity was dampened during the even higher levels of stock market volatility resulting from the onset of the COVID-19 pandemic due to the economic uncertainty caused by the pandemic and concerns about acquiring stock that could continue to decline rapidly. During 2022, however, activists sought to take advantage of depressed stock prices and deteriorating financial outlooks from companies struggling with macroeconomic headwinds. Nonetheless, as discussed in the section titled “Activism Campaign Data Overview”, this increased activity did not lead to higher rates of success for activists.

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Between Public and Private Enterprise: The Role and Structure of Special-Purpose Governments

Conor Clarke is an attorney in the Office of Legal Counsel of the U.S. Department of Justice and Henry Hansmann is the Oscar M. Ruebhausen Professor Emeritus of Law at Yale Law School. This post is based on their recent paper.

Special-purpose governments and the difference between public and private organizations

What is a government as distinguished from a private organization? The term “government” may bring to mind an organization that provides or regulates a broad array of services. But that description fits only a minority—roughly 40,000 — of the 90,000 (mostly local) governments in the United States. The Census labels most American governments “special-purpose” governments, which usually undertake only a single activity, such as water supply, fire protection, or trash collection. There is little between these special-purpose governments and those that provide a broad array of services. That is, there are virtually no two-, three-, or four-purpose governments.

The services provided by special-purpose governments overlap almost completely those provided by general-purpose governments (including counties, municipalities, and townships). Special-purpose governments also resemble, in important respects, private organizations such as cooperatives, condominiums, mutuals, and nonprofits. Examining these institutions together provides an opportunity to pursue fundamental questions concerning the difference between governments and private organizations, as well as the reasons why local governments have the legal and organizational structures that we observe.

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2022 U.S. CEO Outlook

John Rodi is the leader of the KPMG Board Leadership Center (BLC). This post is based on his KPMG memorandum.

Overview

On the heels of the pandemic, CEOs are now facing another turbulent period. Our latest CEO Outlook is being released amid a business environment marred by high inflation, geopolitical tensions and fears of a recession. But the resilience shown during the most challenging days of COVID-19 bodes well for the future.

Featuring insights from more than 1,300 CEOs at large companies globally, including 400 in the United States, the survey finds a majority of U.S. CEOs confident about growth over the next three years and the resilience of their companies in the near term, as they have been preparing for a recession by implementing new strategies to drive efficiency and expansion. They are set on transformative growth via mergers and acquisitions, with a majority considering making strategic deals to propel their businesses.

CEOs are balancing the priorities that have been foundational to our CEO Outlook and looking to turn risk into opportunity by focusing on technology, ESG and talent.

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Activating Sustainability in the Boardroom

Laura Sanderson co-leads the Board and CEO Advisory Partners in Europe and Sarah Galloway is co-head of the Global Sustainability Practice at Russell Reynolds Associates. This post is based on a Russell Reynolds Associates memorandum by Ms. Sanderson, Ms. Galloway, Louise Belloin, Molly Conte, Beth Hawley, and Emily Meneer. Related research from the Program on Corporate Governance includes The Illusory Promise of Stakeholder Governance (discussed on the Forum here) and Does Enlightened Shareholder Value Add Value? (discussed on the Forum here) both by Lucian A. Bebchuk and Roberto Tallarita; Restoration: The Role Stakeholder Governance Must Play in Recreating a Fair and Sustainable American Economy—A Reply to Professor Rock (discussed on the Forum here) by Leo E. Strine, Jr.; Stakeholder Capitalism in the Time of Covid (discussed on the Forum here) by Lucian A. Bebchuk, Kobi Kastiel, and Roberto Tallarita; and Corporate Purpose and Corporate Competition (discussed on the Forum here) by Mark J. Roe.

The business case for sustainability has never been stronger

Organizations are under increasing pressure to create holistic approaches to sustainability and broader Environmental, Social and Governance (ESG) strategies to meet regulatory requirements and societal and investor expectations. At the same time, sustainability also presents an enormous opportunity for value creation to those that develop more sustainable products or solutions.

Russell Reynolds Associates examined the role boards can play in activating sustainability across their organization, setting out:

  • The importance of forging a collaborative relationship with the management team
  • The four key areas of board responsibility when it comes to sustainability
  • Actionable recommendations and examples of implementing effective sustainability oversight

An increasing number of companies are in the process of transforming their business and operating models to deliver sustainable value to their customers, employees, investors, and the wider societal context in which they operate. However, most boards and management teams are struggling with this transition.

Activating sustainable leadership requires a high degree of coordination, starting with the board and senior leadership becoming aligned on the sustainability vision and roadmap, and allowing next-generation leaders and front-line employees to become conduits for embedding the sustainability agenda into the fabric of the organization. This results in more unified messaging when interfacing with customers, suppliers, and other external stakeholders.

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Industry Asset Revaluations around Public and Private Acquisitions

Philip Valta is a Professor of Finance at University of Bern. This post is based on an article forthcoming in the Journal of Financial Economics by Professor Valta, Professor François Derrien, Professor Laurent Frésard, and Professor Victoria Slabik.

Summary of the findings:

We study whether M&A activity improves the informational efficiency of financial markets – i.e., the ability of asset prices to reflect accurately fundamentals. The motivation for our analysis takes roots in two well-known observations. First, announcements of M&A transactions are important events that are closely followed by market participants as they reveal new information about the value of merging firms (e.g., the expected synergies), but also about their respective industries. Second, M&A transactions tend to occur when the market prices of real assets diverge from their fundamental values. To the extent that corporate insiders are better informed about fundamentals than investors (i.e., outsiders) are, they can profit by buying undervalued assets. We posit that when they do so, part of their private information is revealed to outsiders, who can then use this information to revalue other assets in the same industry. A central pillar of financial economics is that information-based trading renders financial markets more informationally efficient. We investigate whether trading in real assets by informed corporate managers might have similar implications. We label this hypothesis the “revaluation” hypothesis.

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ESMA Consultation Paper on Fund Names to Tackle Greenwashing

Paul A. Davies and Nicola Higgs are partners at Latham & Watkins LLP. This post is based on a Latham memorandum by Mr. Davies, Ms. Higgs, Anne Mainwaring and Dianne Bell.

The European Securities and Markets Authority proposes to restrict ESG- and sustainability-related terms in the naming of funds, with an eye on the US and UK fund naming regimes.

On 18 November 2022, the European Securities and Markets Authority (ESMA) published its consultation paper on guidelines in relation to funds’ names, including quantitative thresholds that would need to be met before ESG- and sustainability-related terminology can be used in funds’ names. The proposed rules would set common standards for AIFMs[1] and UCITS[2] management companies when promoting AIFs and UCITS using an ESG- or sustainability-related name, including when these funds are set up as EuVECA, EuSEF, and ELTIFs[3] to facilitate marketing of funds throughout EU Member States.

To avoid misleading investors, ESMA believes that ESG- and sustainability-related terms in funds’ names should be supported materially by evidence of sustainability characteristics or objectives that are reflected fairly and consistently in the fund’s investment objectives and policies.

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