Defined Benefit Combo Cash Balance Compliance Consultant Loren D. Stark Company (LDSCO)
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Apple Must Include Shareholder Proposal on Executive Compensation in Proxy
Winston & Strawn LLP, via Lexology; free registration required Nov. 15, 2016 "The SEC found that: [1] The proposal focuses on senior executive compensation, so that the company could not omit the proposal from its proxy materials in reliance on rule 14a-8(i)(7). [2] The proposal was not so inherently vague or indefinite that neither the shareholders voting on the proposal, nor the company in implementing the proposal, would be able to determine with any reasonable certainty exactly what actions or measures the proposal requires [rule 14a-8(i)(3)]. [3] The company did not lack the power or authority to implement the proposal [rule 14a-8(i)(6)].... [T]his no-action letter is a worrisome development for next year." |
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