Author Archives: Tarik Samman

SEC Staff Publishes New C&DIs on Types of Shareholder Engagement Could Cause Loss of Schedule 13G Eligibility

Today, the Staff in the Division of Corporation Finance at the Securities and Exchange Commission published one new and one revised Compliance and Disclosure Interpretation (C&DI) under Regulation 13D-G. The C&DIs address circumstances in which a greater-than-5% shareholder’s engagement with an issuer’s management could cause the shareholder to be deemed to hold the subject securities […]

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ISS 2025 US Benchmark Policy Guidelines

On December 17, 2024, one of the two most influential proxy advisory firms, ISS, released its Proxy Voting Guidelines Benchmark Policy Changes for 2025: US, Canada, and Americas Regional, which provides updates to its voting policies for the 2025 proxy season. The full 2025 ISS Benchmark Voting Policy document is expected to be published in the coming […]

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The Industry Veteran CEO: Friend or Foe?

Director nominees with CEO experience have long featured in Board slates put forward by activist investors. Those candidates were typically from outside the target company’s industry, and the applicability of their experience was often questioned. However, there is an emerging trend of activist investors utilizing CEOs with direct industry experience at competitor companies, and even […]

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Implications of Tornetta v. Musk II for Executive Compensation and for Stockholder Ratification

In Tornetta v. Musk (Jan. 30, 2024, “Tornetta I”), the Delaware Court of Chancery ordered rescission of the 10-year equity compensation plan for Elon Musk (Tesla, Inc.’s chief executive) that had been approved by Tesla’s board and the stockholders unaffiliated with Musk. Under the plan, Musk was awarded several tranches of performance-vesting stock options, with an estimated […]

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The Evolving Anti-DEI and Anti-ESG Landscape: Implications for the Public Sector

Boards will seek to minimize their legal and regulatory risks, particularly considering that DEI and ESG programs face increased hostility. On January 21, 2025, President Donald Trump issued Executive Order 14173. The main thrust of this Executive Order (“EO”) was to eliminate “illegal” Diversity, Equity, and Inclusion (“DEI”) programs across all federal agencies. Additionally, the […]

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Weekly Roundup: February 7-13, 2025

Delaware’s Rocky Year–What Lies Ahead? Posted by Mark E. McDonald, Roger A. Cooper, and Peter Carzis, Cleary Gottlieb Steen & Hamilton LLP, on Friday, February 7, 2025 Tags: Board of Directors, Delaware Court of Chancery, DGCL, stockholders A New Regulatory Environment for Climate and Other ESG Reporting Rules Posted by Amelie Champsaur, Helena Grannis, and […]

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The Transformation of the CEO: Global CEO Turnover Index Annual Report

Chapter One: A record year for elections and CEO turnover With almost half the world’s population involved in national elections, 2024 was a year characterized by change, so it is perhaps no surprise to see the recent trend of high CEO turnover reach a new peak with record departures reported. The latest figure of 202 […]

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Caremark’s Fractured State

Delaware’s hegemony in U.S. corporate law is indisputable. Law students are taught Delaware corporate law, and corporate law practitioners are expected to be well-versed in Delaware’s doctrinal nuances. Regardless of one’s opinion about the benefits provided by Delaware incorporation, Delaware’s preeminence has created a shared corporate law language that bridges jurisdictional boundaries. The Caremark doctrine […]

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Recent Developments for Directors

New SEC Chair Expected to Take Agency Back to Basics President Trump’s nominee for SEC Chair, Paul Atkins, advocates a business-friendly, light-touch regulatory philosophy and is expected to lead the agency to retether its rulemaking to the SEC’s three-part statutory mission — facilitating capital formation; protecting investors; and maintaining fair, orderly, and efficient markets. Atkins […]

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Voting on ESG: A Gap Becomes a Gulf

Key Observations U.S. support for E&S proposals fell further in 2024.  U.S. managers further reduced their backing for environmental and social (E&S) proposals in the 2024 proxy year. Average support by 20 large U.S. firms for significant E&S shareholder resolutions funds fell to 31% in 2024 from a 2021 peak of 54%. For the first […]

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