Issue link: https://digital.shearman.com/i/1035494
Shearman & Sterling LLP Shareholder Engagement: Using Proxy Statements and Corporate Websites | 31 Core Governance Documentation of the Top 100 Companies post their corporate governance guidelines on their website of the Top 100 Companies post their certificate of incorporation on their website of the Top 100 Companies post their compensation committee charter on their website of the Top 100 Companies post their code of business conduct/ethics on their website of the Top 100 Companies post their by-laws on their website of the Top 100 Companies post their nominating and governance committee charter on their website of the Top 100 Companies post their audit committee charter on their website of the Top 100 Companies post all of their committee charters on their website Applicable SEC rules and the listing standards of the stock exchanges require that companies post their corporate governance guidelines, code of business conduct/ethics and the charters of their audit, compensation and nominating and governance committees on their corporate websites (or publish them at least every three years in their proxy statements). In practice, nearly all of the Top 100 Companies post these documents on their corporate websites. CORPORATE WEBSITE DISCLOSURES 100% 70% 100% 100% 80% 100% 100% 84% As there is no rule requiring that companies post other core corporate governance documentation to their corporate websites, there is more variability in this practice. Many companies that had an executive committee did not post the executive committee charter on the corporate website. Of the 36 companies that disclosed they had an executive committee, only 27 companies posted the executive committee charter. CORPORATE SOCIAL RESPONSIBILITY (CSR) REPORT 82% of the Top 100 Companies published Corporate Social Responsibility Reports (CSRs) or devote entire sections of their website to disclosing their role as "corporate citizens"