Yearly Archives: 2023

Boardwalk Pipeline v. Bandera

Gail Weinstein is Senior Counsel, Steven J. Steinman and Brian T. Mangino are Partners at Fried, Frank, Harris, Shriver & Jacobson LLP. This post is based on a Fried Frank memorandum by Ms. Weinstein, Mr. Steinman, Mr. Mangino, Steven Epstein, Randi Lally and Mark H. Lucas, and is part of the Delaware law series; links to other posts in the series are available here. Related research from the Program on Corporate Governance includes Independent Directors and Controlling Shareholders (discussed on the Forum here) by Lucian Bebchuk and Assaf Hamdani.

In Boardwalk Pipeline Partners, LP v. Bandera Master Fund LP (Dec. 19, 2022), the Delaware Supreme Court reversed a Court of Chancery decision (Nov. 12, 2021) that had ordered the general partner of Boardwalk (a master limited partnership) to pay the former public unitholders almost $700 million in damages in connection with the general partner’s $1.56 billion take-private of Boardwalk.

Notably, the Supreme Court did not overturn the Court of Chancery’s factual findings that the General Partner and its affiliates had (i) opportunistically timed the take-private to occur during a temporary period of regulatory uncertainty and declining prices for Boardwalk’s units, and (ii) manipulatively pressured their law firm to deliver a “contrived,” “sham” opinion to satisfy the sole condition to the general partner’s exercise of its call right to acquire the public units. Nonetheless, the Supreme Court overturned the Court of Chancery’s legal holding that the general partner was liable for willful misconduct.

Instead, the Supreme Court viewed the general partner as simply having made “full use” of the broad “flexibility” a controller is permitted under Delaware law when its fiduciary duties have been contractually eliminated and the absence of those duties has been fully disclosed to investors. “The Partnership Agreement allowed Boardwalk to exercise the call right to its advantage—and to the disadvantage of the minority unitholders—free from fiduciary duties,” the Supreme Court wrote. The Supreme Court also held that the opinion of counsel the general partner obtained satisfied the contractual condition to exercise of the call right. The Supreme Court stated that the “proper focus” for the court was not on the validity of the legal opinion but on whether the general partner had acted reasonably in relying on it. The general partner had acted reasonably in relying on it, the Supreme Court concluded, based on its having obtained and relied on a second opinion from another law firm—which was not challenged—that opined that it would be within the general partner’s reasonable judgment to decide to rely on the first opinion. As the partnership agreement provided a conclusive presumption of good faith for the general partner when relying on advice of counsel, the general partner was presumed not to have engaged in willful misconduct and was entitled to exculpation from damages.

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Proxy voting policy for U.S. portfolio companies

John Galloway is Global Head of Investment Stewardship at Vanguard, Inc. This post is based on a publication by Vanguard Investment Stewardship.

Introduction

The information below, organized according to Vanguard Investment Stewardship’s four principles, is the voting policy adopted by the Boards of Trustees of the Vanguard-advised funds (the “Funds’ Boards”)[1] and describes the general positions of the funds on proxy proposals presented for shareholders to vote on by U.S.- domiciled companies.

It is important to note that proposals often require a facts-and-circumstances analysis based on an expansive set of factors. Proposals are voted case by case, under the supervision of the Investment Stewardship Oversight Committee and at the direction of the relevant Fund’s Board. In all cases, proposals are voted as determined in the best interests of each fund consistent with its investment objective.

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Corporate Officers, Not Just Directors, Can Be Liable for Duty of Oversight Violations

Jonathan K. Youngwood, Nicholas Goldin, and Stephen Blake are Partners at Simpson Thacher & Bartlett LLP. This post is based on their Simpson Thacher memorandum and is part of the Delaware law series; links to other posts in the series are available here. Related research from the Program on Corporate Governance includes Monetary Liability for Breach of the Duty of Care? (discussed on the Forum here) by Holger Spamann. 

In an important opinion that will have significant implications for derivative lawsuits arising from corporate crises, ESG issues and financial challenges, Vice Chancellor Laster on January 25, 2023 denied a motion to dismiss a derivative lawsuit alleging that the former head of human resources (“Defendant”) for global fast food company McDonald’s breached his fiduciary duties by (i) consciously ignoring red flags regarding sexual harassment and misconduct at the company and (ii) personally engaging in sexual harassment. In re McDonald’s Corp. S’holder Derivative Litig., No. 2021-0324, 2023 WL 387292 (Del. Ch. Jan. 25, 2023).

Vice Chancellor Laster announced that “[t]his decision clarifies that corporate officers owe a duty of oversight[,]” rejecting Defendant’s contention that Delaware law does not impose obligations on corporate officers that are comparable to the duty of oversight articulated for directors in In re Caremark International Inc. Derivative Litigation, 698 A.2d 959 (Del. Ch. 1996).

In concluding that Defendant owed a duty of oversight, the court explained that Defendant “had an obligation to make a good faith effort to put in place reasonable information systems so that he obtained the information necessary to do his job and report to the CEO and the board, and he could not consciously ignore red flags indicating that the corporation was going to suffer harm.”

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ESG in 2023: Politics and Polemics

David A. Katz is a Partner and Laura A. McIntosh is a Consulting Attorney at Wachtell, Lipton, Rosen & Katz. This post is based on their Wachtell memorandum. Related research from the Program on Corporate Governance includes The Illusory Promise of Stakeholder Governance (discussed on the Forum here) and For Whom Corporate Leaders Bargain (discussed on the Forum here) both by Lucian A. Bebchuk and Roberto TallaritaRestoration: 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 Bebchuk, Kobi Kastiel, and Roberto Tallarita.

ESG is poised to become a major element of nonfinancial reporting at the very moment that it is becoming highly controversial and politicized.  New European Union rules regarding mandatory ESG reporting will affect public and private U.S. companies that meet certain EU-presence thresholds or—significantly—are part of the value chain of an entity that is required to make the mandatory disclosures.  This development represents a significant departure from past practices and will reach much farther than many companies may have anticipated.  In the United States, the Securities and Exchange Commission is on the verge of adopting climate-related disclosure rules, possibly heralding the start of increasingly onerous ESG reporting obligations.  These regulatory developments are supported by many, though not all, institutional investors, and the extent of such support going forward is likely to influence the future direction of ESG disclosure.

Over the past year, an anti-ESG backlash has flourished in the United States, led by conservative politicians and investors.  Florida governor Ron DeSantis summarized the thesis of the backlash in a recent statement:  “Corporate power has increasingly been utilized to impose an ideological agenda on the American people through the perversion of financial investment priorities under the euphemistic banners of environmental, social, and corporate governance and diversity, inclusion, and equity.”  At the World Economic Forum summit in Davos last week, a number of executives expressed frustration and concern over the intensifying drama around ESG.  Like it or not, however, executives and investors will have to contend with ESG controversies and disclosure obligations for the foreseeable future while staying focused on their strategic priorities.  Proactive board oversight—of both ESG disclosure practices and ESG-related controversies—will be essential to managing companies’ reputational risk strategy around ESG.

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Does Greater Public Scrutiny Hurt a Firm’s Performance?

Benjamin Bennett is Assistant Professor at the Tulane University A.B. Freeman School of Business; René M. Stulz is the Everett D. Reese Chair of Banking and Monetary Economics at the Fisher College of Business at The Ohio State University; and Zexi Wang is an Associate Professor at the Lancaster University School of Management. This post is based on their recent paper.

CEOs are often concerned about the public scrutiny that comes with leading a public firm. Founders want their firm to stay private to avoid that scrutiny. Public scrutiny can be valuable, however, as it can lead to more monitoring of firms, which may improve performance. At the same time, greater attention can have adverse effects. For instance, it can distract managers, preventing them from spending their time on issues internal to the firm, and can make it difficult for firms to stand out and implement policies that may be unpopular with the public. Consequently, while public attention may have a positive side, it may also have a dark side. In this paper, we investigate whether public scrutiny benefits firm performance. We find evidence that an increase in public scrutiny has an adverse effect on firm performance.

Public attention varies among public firms. Some firms consistently receive more attention because they are more prominent or salient. For firms subject to more scrutiny, mistakes may have larger consequences as they are noticed more. Policy differences with comparable firms will be better known and raise more questions. Firm actions may be more likely to be noticed and criticized by politicians. The firm may become more exposed to legal and regulatory actions. As a result, greater attention could affect performance negatively and may force firms to take actions they would not take absent the greater attention. For instance, greater public attention might cause management to choose policies more similar to those of peers even if it would not do so in the absence of greater public scrutiny. Management might do so because it does not want its policies to stand out, because sectors of the public push for such policies, or because these policies are optimal given the heightened attention. We therefore investigate whether one channel through which greater public attention affects performance is in causing firms with greater attention to have policies more similar to their peers.

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Expanding and Diversifying Director Candidate Pools through Subsidiary Board Service

Michael Rossen is a Managing Director and Kay Brkic is a Senior Manager at Deloitte LLP. This post is based on a Deloitte LLP memorandum by Mr. Rossen, Ms. Bkic, Richard Levine, and Ian MacDonald. Related research from the Program on Corporate Governance includes Politics and Gender in the Executive Suite (discussed on the Forum here) by Alma Cohen, Moshe Hazan, and David Weiss; Will Nasdaq’s Diversity Rules Harm Investors? (discussed on the Forum here) by Jesse M. Fried; and Duty and Diversity (discussed on the Forum here) by Chris Brummer and Leo E. Strine, Jr.

The business case for board diversity is not new and may no longer be forward-thinking.[1] While organizations – and other parties – have introduced initiatives to encourage boardroom diversity, developing the next generation of board members is a persistent challenge for many business leaders.

Beyond current initiatives to increase boardroom diversity, organizations with subsidiaries are uniquely positioned to further diversify the board candidate pool.

As an example, organizations can place diverse executives onto their subsidiary boards. By providing this opportunity to their executives through a formalized policy, organizations can fill subsidiary boards with those that are interested in board service, and the executives can gain valuable experience of serving on a board that can be used as a steppingstone for longer-term board service aspirations should they wish. Putting such a policy in place also sets the stage to infuse diverse candidates into future parent board refreshment initiatives. However, this approach may not be as simple for listed subsidiaries that will have their own requirements for outside, independent directors.

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Global Corporate Credit ESG Engagement Report

Jonathan Bailey is a Managing Director and Head of ESG Investing, and Savannah Irving is an Associate at Neuberger Berman LLC. This post is based on their Neuberger Berman memorandum.

In recent years a variety of market disrupting events have underscored the importance of active ownership and the analysis of material environmental, social and governance (ESG) factors in fundamental credit research as well as investment decision-making. In our view, asset managers who leverage their relationships with issuers are best positioned to manage these ESG risks and take advantage of ESG opportunities. As highlighted in our prior ESG engagement reports, Neuberger Berman views direct issuer engagement as a critical tool to mitigate portfolio risks while generating long-term sustainable returns.

During the past year our established relationships with issuers in developed and emerging markets enabled us to have meaningful engagements with a number of management teams. We engaged on key ESG issues such as climate change, community relations and human capital management. While these ESG issues present varying challenges and complexities, both transparency and accountability are key determinants of the success of our engagements with corporate credit issuers. We encourage issuer alignment with external frameworks such as the United Nations Sustainable Development Goals (UN SDGs), the Task Force on Climate-Related Financial Disclosures (TCFD) and the SASB Standards to improve the transparency of issuers’ credit profiles. We also assess the capability of management teams to set and successfully execute sustainability targets, as evidenced in the emerging practice of linking ESG Key Performance Indicators (KPIs) to executive variable compensation with a focus on enhancing accountability.

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Investing in Influence: Investors, Portfolio Firms, and Political Giving

Raymond Fisman is Slater Family Professor in Behavioral Economics at Boston University. This post is based on a recent paper by Professor Fisman, Marianne Bertrand, Matilde Bombardini, Francesco Trebbi, and Eyub Yegen. Related research from the Program on Corporate Governance includes The Agency Problems of Institutional Investors (discussed on the Forum here) by Lucian Bebchuk, Alma Cohen, and Scott Hirst; Index Funds and the Future of Corporate Governance: Theory, Evidence, and Policy (discussed on the Forum here) and The Specter of the Giant Three (discussed on the Forum here) both by Lucian Bebchuk and Scott Hirst; and The Limits of Portfolio Primacy (discussed on the Forum here) by Roberto Tallarita.

Over the past seventy years, institutional investors’ ownership of publicly traded U.S. companies has increased dramatically, from just 6 percent in 1950 to 65 percent in 2017. As a result, a large fraction of the U.S. economy is now in the hands of a relatively small number of asset management companies. The “Big Three” of BlackRock, Vanguard, and State Street Global Investors, for example, held more than 20 percent of S&P 500 shares in 2017 as compared to 5 percent in 1998.

This sea change in the ownership of U.S. corporations has given rise to a discussion among academics and policymakers over its consequences. In “Investing in Influence,” we focus on a particular concern over the rise of institutional shareholders: has the concentration of ownership also led to a concentration of political influence?

Researchers – including ourselves – have traditionally assumed that companies’ political strategies were simply an extension of their profit-maximizing business strategies. Under this view of the world, firms make campaign donations or lobby regulators to secure laws and regulations that are good for company profits. Yet a vast body of research on corporate governance has shown that companies’ goals are driven not by a single-minded focus on corporate profits, but rather a collection of disparate interests of those who wield control over the firm’s resources.

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Weekly Roundup: January 27-February 2, 2023


More from:

This roundup contains a collection of the posts published on the Forum during the week of January 27-February 2, 2023

Preparing for the 2023 Proxy Season


Update on ESG, Stakeholder Governance, and Corporate Purpose


Delaware Courts Provide Guidance on Incumbent Board Enforcement of Advance Notice Bylaws


EU Finalizes ESG Reporting Rules with International Impacts


The controversy over proxy voting: The role of asset managers and proxy advisors


Voting Rights in Corporate Governance: History and Political Economy


​Antitrust and ESG


Conflicting Fiduciary Duties and Fire Sales of VC-backed Start-ups


Where is the World Going in 2023 and Beyond?


​Delaware M&A Updates


ESG Investing After the DOL Rule on “Prudence and Loyalty in Selecting Plan Investments and Exercising Shareholder Rights”


ESG Investing After the DOL Rule on “Prudence and Loyalty in Selecting Plan Investments and Exercising Shareholder Rights”

Robert H. Sitkoff is Austin Wakeman Scott Professor of Law and John L. Gray Professor of Law at Harvard Law School, and Max M. Schanzenbach is Seigle Family Professor of Law at Northwestern Pritzker School of Law. Related research from the Program on Corporate Governance includes The Illusory Promise of Stakeholder Governance (discussed on the Forum here) by Lucian A. Bebchuk and Roberto Tallarita; Companies Should Maximize Shareholder Welfare Not Market Value (discussed on the Forum here) by Oliver D. Hart and Luigi Zingales; and Reconciling Fiduciary Duty and Social Conscience: The Law and Economics of ESG Investing by a Trustee (discussed on the Forum here) by Robert H. Sitkoff and Max M. Schanzenbach.

Summary of the Rule

In late 2022, the Department of Labor under President Biden promulgated a new rule on “Prudence and Loyalty in Selecting Plan Investments and Exercising Shareholder Rights,” superseding the Department’s 2020 rule promulgated under President Trump. Numerous media reports suggested that the 2022 Biden Rule permits or even encourages ESG investing, in contrast to the 2020 Trump Rule, which was reported to be hostile to ESG investing. These reports are wrong. This summary aims clarify the effect of the Biden Rule and what has changed from the Trump Rule.

In brief, the 2022 Biden Rule largely reaffirms the Department of Labor’s longstanding position, compelled by binding Supreme Court precedent, that an ERISA fiduciary may use ESG investing to improve risk-adjusted returns but not to obtain collateral benefits. Subject to a few nuanced changes of limited practical import, the Biden Rule is largely consistent with the 2020 Trump Rule and earlier regulatory guidance.

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