September 28, 2007
Chairman Christopher Cox
Securities and Exchange Commission
100 F Street, NE Washington, DC 20549-1090
Dear Chairman Cox,
I write in the name of a faith-based institutional investor, the General Administration of the Religious of the Sacred Heart of Mary, to express our opposition to any attempt to weaken or cripple shareholders right to file non-binding advisory resolutions under Rule 14a-8.
For over three decades, shareholder proposals have provided large and small shareholders with a voice in the governance of corporations on which their financial futures depend. This has been true for our Institute. We believe that shareholder proposals have helped to promote corporate transparency and accountability, as well as improving corporate governance and performance. They have called attention to important issues ranging from greenhouse gas emissions, global warming, nuclear power, and sweatshops to executive compensation. When not addressed, these major societal and environmental problems have often ended up costing shareholders and their companies as a result of lawsuits, damaged reputations, consumer boycotts, public protests and low staff morale.
The current proxy rules have facilitated a rich and diverse dialogue addressing some of the most critical issues of our time by ensuring shareholder democracy. We urge you to keep these current rules in place and ask that the commission safeguard, not undermine their use.
We are aware that engaged investors across the county are prepared to publicly defend their ownership rights should those be threatened by proposed rulemaking. We hope that the SEC will consider how to enhance the dialogue between corporations and their owners on matters of strategic importance.
Yours sincerely,
Sr. Veronica Brand RSHM
General Treasurer – Religious of the Sacred Heart of Mary