Monthly Archives: July 2024

Advance Notice Bylaws After Kellner: Still Advisable and Require Not Flying Too Close to the Sun

Leonard Wood, Kai H. E. Liekefett, and Derek Zaba are Partners at Sidley Austin LLP.

There has never been a more important time for public companies traded on U.S. stock exchanges to have appropriate, robust advance notice bylaws. These provisions protect the interests of all shareholders by ensuring a fair process in relation to the conduct of corporate director elections and shareholder nominations of director candidates. Companies and shareholders benefit from robust advance notice bylaws because shareholder activists annually knock on the doors of a staggering number of U.S. public companies each year bearing dissident director nominations and other business proposals, with unpredictable and, in some cases, harmful consequences. Since January 2022, activists initiated over 900 public campaigns at corporations traded in the U.S., based only on publicly available data.[1] At the same time, over the past two years, a spate of high-profile lawsuits in Delaware challenging the validity of advance notice bylaws created uncertainty, for Delaware corporations as well as corporations of other states, about the legality and advisability of adopting new advance notice bylaws or modifying those that companies already had in place.

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The Potential Impact of the DGCL Market Practice Amendments on Activism Settlements

Keith E. Gottfried is Founder and CEO of Gottfried Shareholder Advisory. This post is based on his Gottfried memorandum and is part of the Delaware law series; links to other posts in the series are available here.

On July 17, 2024, Senate Bill 313, the market practice amendments to the Delaware General Corporation Law (the “DGCL”), were signed into law by Delaware Governor John Carney and are now incorporated into the DGCL.  Prior to such time, the debate had already begun over how the market practice amendments would impact companies’ settlements with activist investors and whether the “floodgates” would be opened for more expansive demands from activists in connection with such settlements.

Since at least the early 2000’s, activism settlement agreements (also known as cooperation agreements) have become relatively standardized in overall form with the key feature being that the company’s board agrees to appoint and/or nominate and recommend to shareholders one or more activist recommended director candidates and, following the appointment by the board or election by the shareholders, to appoint such director candidates to one or more existing or new board committees. In return, the activist agrees to withdraw its notice of nominations and terminate its proxy contest, agrees to various standstill and other restrictive covenants for a limited period of time, and agrees to vote for the company’s slate of director nominees which would include the activist’s recommended director candidates. The company may also agree to various other provisions such as a limit on the size of the board during the standstill period, certain governance reforms requested by the activist such as declassification of a classified board, and expense reimbursement for the activist.

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Weekly Roundup: July 19-25, 2024


More from:

This roundup contains a collection of the posts published on the Forum during the week of July 19-25, 2024

AI Washing Enforcement Continues, Highlighting Risks to Companies and Investors


Supreme Court rules SEC use of in-house tribunals is unconstitutional


Supreme Court’s Overruling of Chevron Will Invite More Challenges to Agency Decisions


AI: Are Boards Paying Attention?


How Companies React to Say on Pay Failures


Driving Audit Quality Forward: Where We’ve Been and Where We’re Heading


NYC Pension Plan Suit is Thrown Out, GOP Anti-ESG Fiduciary Duty Theory Remains to be Tested



Environmental Performance Metrics in Incentive Plans: Incentive Trends and Key Design Considerations


The Supreme Court rebalances the administrative state


The Defensive Measures Provisions of the EU Takeover Directive: From Ambition to Resignation to Distrust


Compensation Clawbacks Report


Delaware Supreme Court Clarifies Standards Applicable To Advance Notice Bylaws


Conflicted Regulators


Spotlight on Chief Financial Officers


Spotlight on Chief Financial Officers

Kelly Malafis is a Founding Partner, Roman Beleuta is a Principal, and Louisa Heywood is an Associate at Compensation Advisory Partners. This post is based on their CAP memorandum.

CAP’s report examines compensation outcomes for Chief Financial Officers (CFOs) relative to Chief Executive Officers (CEOs). This analysis summarizes 2023 compensation actions among 132 companies with median revenue of $14.6 billion. Additional criteria used to develop the sample is included in the Appendix.

Study Highlights

Base Salary

The median change in base salary in 2023 was 4.0% for CFOs, similar to last year’s 3.8% increase. For CEOs, the median salary change was 0%, well below last year’s 2.9% median increase

  • Over 70% of CFOs and half of CEOs received base salary increases this past year. This is similar to 2022 when 75% of companies made salary increases for CFOs and 56% made increases for CEOs
  • Among executives who received salary increases, the median increase was 5.0% for CFOs and 4.0% for CEOs. These increases were similar to the prior year’s increases (5.1% for CFOs and 4.7% for CEOs) and align with higher salary budgets that we saw emerge in the post-pandemic inflationary environment. However, we expect salary increases to level off as companies navigate the current labor market

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Conflicted Regulators

Mathew Kubic and Sara Toynbee are Assistant Professors of Accounting and Rui Silva is a PhD student at the University of Texas, Austin. This post is based on their working paper

Independence is an important feature of financial reporting oversight, contributing to public trust in capital markets. To guard against conflicts of interest that may impair independence, regulatory agencies typically have policies restricting employees’ financial and personal relationships with regulated entities. For example, workers moving from the private to the public sector are often subject to cooling-off periods that exclude them from decisions involving their prior employers for some time. Although such cooling-off policies are commonplace, there is little empirical evidence on the optimal design of such policies, such as their scope and length. In a working paper, we explore how prior employment affiliations of examiners in the Securities and Exchange Commission’s (SEC) filing review program affect the strictness of their oversight.

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Delaware Supreme Court Clarifies Standards Applicable To Advance Notice Bylaws

Arthur R. BookoutJoseph O. Larkin and  Jenness E. Parker are Partners at Skadden, Arps, Slate, Meagher & Flom LLP. This post is based on a Skadden memorandum by Mr. Bookout, Mr. Larkin, Ms. Parker, and Gregory P. Ranzini and is part of the Delaware law series; links to other posts in the series are available here.

On July 11, 2024, the Supreme Court of Delaware, en banc, issued an important decision in Kellner v. AIM Immunotech Inc.,1 which arose from a challenge in the Delaware Court of Chancery involving advance notice bylaws that were adopted in the wake of the recent universal proxy rules.

The Supreme Court engaged in a detailed analysis of the post-trial rulings below and clarified the standards of review for determining the validity and enforceability of such bylaws. Ultimately, the court affirmed in part, and reversed in part, the rulings below.

The decision provides important guidance to companies and boards in a developing area of law, and may spur challenges against similar bylaws.

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Compensation Clawbacks Report

Neil McCarthy is Co-Founder and Chief Product Officer, James Palmiter is CEO and Co-Founder, and G. Michael Weiksner is Co-Founder and Chief Technology Officer at DragonGC. This post is based on a DragonGC memorandum by Mr. McCarthy, Mr. Palmiter, Mr. Weiksner, and Jennifer Carberry.

DragonGC’s latest report sheds light on the evolving landscape of compensation clawback policies among S&P 500 companies. This comprehensive study, which analyzed 401 companies that filed independent clawback policy disclosures within the past 12 months (for period ended May 7, 2024), reveals a significant trend: a majority of these companies are not only meeting but exceeding the SEC’s requirements. This proactive approach underscores a commitment to enhanced corporate governance and accountability.

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The Defensive Measures Provisions of the EU Takeover Directive: From Ambition to Resignation to Distrust

Paul L Davies is Emeritus Professor of Corporate Law at Harris Manchester College, University of Oxford. Alain Pietrancosta is Professor of Law at Sorbonne Law School, University of Paris. This post is based on their recent working paper.

This year is the 20th anniversary of the adoption by the European Union of its Directive on Takeovers. A group of scholars associated with the European Corporate Law Experts Group (ECLE) has compiled a set of papers assessing the performance of the Directive. One of these papers is concerned with the Directive’s rules on defensive measures in response to tender offers. It assesses them predominantly from an industrial policy perspective.

During the (very lengthy) negotiations among the Member States, the European Commission was enthusiastic about the benefits of removing barriers to takeovers, on the grounds that making the control of companies contestable would both help to solidify the Union’s internal market and strengthen European companies in global competition. Some Member States were less convinced. A notable expression of this opposition was the actions of the German government which in 2001 blocked at the very last minute in the Union’s legislative procedure the adoption of a version of the Directive which contained a prohibition on post-bid defensive measures unless a majority of the shareholders gave their consent in the face of the bid – the so-called board neutrality rule (BNR). This was the result of an assessment in Germany of the implications of the takeover of Mannesmann by the British bidder Vodafone in 1999. This reaction was surprising, since the bid had strong internal market credentials and didn’t give rise to ‘level playing field’ concerns, as the UK’s rules were (and still are) favourable to takeovers.

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The Supreme Court rebalances the administrative state

Margaret E. Tahyar and Joseph A. Hall are Partners and David A. Zilberberg is a Counsel at Davis Polk & Wardwell LLP. This post is based on a Davis Polk memorandum by Ms. Tahyar, Mr. Hall, Mr. Zilberberg, Loyti Cheng, Paul D. Marquardt, and Mario Verdolini.

Introduction

The 2023−2024 Supreme Court term continued a strong rebalancing of power among the courts, the administrative state and, if it pays attention, Congress. This rebalancing will impact how executive branch and independent agencies engage in rulemaking, issue guidance and engage in enforcement. Courts will exercise more independent judgment and look more critically at agency actions. Nonetheless, agencies continue to have significant power, authority and discretion. We do not believe that the rebalancing will result in an immediate seismic shift in the administrative state as predicted by some media commentators. When Chevron U.S.A. Inc. v. Natural Resources Defense Council, Inc. was decided in 1984, it took years for its implications of strong deference to administrative agencies to be widely understood. Similarly, it will take years to understand the full import of the new status quo. We expect an uptick in litigation, rather than a “blitzkrieg” or “tsunami.” We agree with those commentators who have observed that litigation challenging agency actions will not be brought solely by regulated entities, but also stakeholders that favor greater regulation. Future litigation will not necessarily favor one set of interests over another. This update briefs on the main themes in the new status quo and what it means for the future.

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Environmental Performance Metrics in Incentive Plans: Incentive Trends and Key Design Considerations

Tara Tays is a Partner, Phil Johnson is a Senior Consultant at Pay Governance, and Ashley Gamarra is Head of Marketing at SustainaBase. This post is based on their Pay Governance memorandum.

Introduction

In recent years, global companies have grappled with defining a baseline for environmental metrics, establishing the processes and controls to measure and report progress toward objectives, and setting the goals of ambitious environmental performance metrics (especially if environmental performance metrics are used in executive incentive arrangements). Institutional investors have also been increasingly seeking ways to ensure that the companies in which they invest are actively working towards a sustainable future. In response to these investors pushing for progress on sustainability (among other priorities), the majority of S&P 500 companies have released sustainability reports, and boards of directors, compensation committees, and management teams have been discussing whether a portion of executives’ incentive compensation programs should be tied to corporate sustainability priorities.

From setting greenhouse gas (GHG) emissions reduction targets to promoting circular economy practices (which involve minimizing waste and maximizing the reuse and recycling of resources), some compensation committees have considered if there are specific and actionable performance metrics that should be included in executive incentive plans. Whether environmental incentive metrics will support meaningful sustainability progress depends on how the metrics are created, measured, and evaluated.

In this article, we explore the role “E” in Environmental, Social, and Governance (ESG) priorities has played in executive incentive arrangements, as well as design considerations for including an “E” metric in executive incentive plans.

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