In its four letters, the company provided a wide-range of in-depth information, including statistical data, analysis by leading economists, and the results of independent reviews. The letters provided detailed information on vote accuracy, process efficiency and voter participation.
“The information in these letters demonstrates that the U.S. proxy system functions well and achieves the primary purposes of the proxy rules – to ensure that companies are able to distribute proxy materials to shareholders in a cost-efficient and timely manner, shareholders are given information that is material to their voting decisions in a timely manner, and proxies are timely and accurately collected and tabulated,” said Richard J. Daly, Chief Executive Officer, Broadridge.
In the October 6th letter on Vote Accuracy Broadridge said that aspects of the system it administered helped achieve goals of vote accuracy, process integrity and transparency, and were consistently found to be reliable by a variety of constituencies and independent parties. Full text of the Vote Accuracy letter can be found by clicking here.
In its October 14th letter on Process Efficiency, the company said it supports the needs of the most efficient and liquid markets in the world and ever-evolving and expanding regulatory requirements and that its systems, technologies, and scale create significant efficiencies for all constituencies involved in the proxy distribution process, including corporate issuers, shareholders, brokers and banks.
This letter further provided that, “The recurring savings on printing and postage alone exceed the service fees paid by several orders of magnitude. These savings result largely from significant ongoing levels of private-sector investment by Broadridge and our technology innovations.” Full text of the Process Efficiency letter can be found by clicking here.
On Voter Participation, its letter of October 19th provided that issuers are afforded a variety of methods to communicate; shareholders are provided a variety of methods to vote without sacrificing privacy preferences and that overall voting rates among beneficial shareholders are high. It recognized voting participation among retail shareholders is a concern and that technologies it provides are providing opportunities to efficiently increase participation. Full text of the Voter Participation letter can be found by clicking here.
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