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SEC Staff Adopts Significant New Guidance Affecting Shareholder Proposals and Engagement

On February 11 and 12, 2025, the staff of the Division of Corporation Finance (Staff) of the Securities and Exchange Commission (SEC) provided a pre-Valentine’s Day treat for public companies and shareholders to digest in the...more

Climate and Sustainability Regulations: 2024 End-of-Year Review

2024 was an active year for environmental, social and governance (ESG) regulations, voluntary reporting standards, and stakeholder policies. While the incoming Trump administration is expected to halt federal sustainability...more

Comparing the SEC Climate Rules to California, EU and ISSB Disclosure Frameworks

The Securities and Exchange Commission (SEC) adopted its long-awaited climate disclosure rules on March 6, 2024. (For more information, see our recent Cooley client alert, webinar and resource page.) The final rules require...more

ISS and Glass Lewis Update 2024 Proxy Voting Policies

Institutional Shareholder Services (ISS) and Glass Lewis, the two most influential proxy advisory firms, recently released updates to their voting policies for the 2024 proxy season. The ISS US policy update will apply for...more

Key Considerations for Form 8-K Cybersecurity Materiality Determinations

With 8-K reporting obligations for “material” cybersecurity incidents under the new Securities and Exchange Commission (SEC) rules becoming effective as of December 18, 2023, most companies will soon be tasked with making...more

California GHG Emissions and Climate Risk Bills Near Finalization

Last week, the California Legislature passed two far-reaching climate disclosure bills – SB 253, the Climate Corporate Data Accountability Act (CCDAA), and SB 261, the Climate-Related Financial Risk Act (CRFRA) – together,...more

SEC Adopts Comprehensive Cybersecurity Disclosure Requirements

On July 26, 2023, the Securities and Exchange Commission (SEC) voted at an open meeting to adopt final rules to mandate standardized cybersecurity disclosures by public companies. The final rules will...more

ESG Ratings: Considerations in Advance of Proxy Season

As companies prepare for the 2023 proxy season, their ESG performance, as evaluated and rated by various third-party ratings providers, is a key focus. With the growing importance of ESG to institutional investors,...more

Life Sciences ESG Reporting Practices

For companies of all industries, ESG matters have become an area of intense focus. In addition to investor and activist pressure, the growth of ESG ratings – and proposed climate and broader ESG disclosure requirements in the...more

Misleading ESG Claims – Will They Wash?

‘Greenwashing’ is the practice of a company providing information on its environmental, social and corporate governance (ESG) policies, or its products and practices, with the intent to present an environmentally responsible...more

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