Sodali’s comment letter to the ESMA Discussion Paper – an overview of the Proxy Advisory Industry

In a June 20, 2012 letter commenting on ESMA’s Discussion Paper on the Proxy Advisory Industry, Sodali recommends that ESMA broaden the scope of its investigation beyond the activities of Proxy Advisors and makes the following specific recommendations:

- the creation of a Code of Governance and Conduct for Institutional Investors and their agents;
- guidelines for the conduct of proxy advisors, including a prohibition on the issuance of vote recommendations in proxy contests;
- a self-administered Code of Conduct for the proxy advisory industry.