"[Steven Hall & Partners is] very concerned about any approach which limits the ability of our clients to predict with certainty whether or not they are likely to secure a favorable vote recommendation from ISS before the proxy is filed.... An unexpected Against vote recommendation from ISS can be very disruptive, and requires a last minute mobilization of resources which is expensive, time-consuming and distracting. We believe shareholders would be better served by a process which permits companies to weigh plan design trade-offs in a thoughtful and deliberate way with full knowledge of how these choices will impact the ISS vote recommendation before making the decision which they believe to be in the best interests of shareholders. This would permit appropriate and timely engagement with shareholders, if required."  MORE >>