Boston Common Asset Management Letter

Boston Common Asset Management is a global investment manager that specializes in sustainable and responsible global equity strategies. On behalf of its clients, Boston Common focuses its shareowner engagement with companies including through the shareholder proposal and proxy voting process on improving transparency on material ESG issues through smarter disclosure, encouraging accountability, inclusiveness, and ethical corporate practices, and managing for the long term.  Participating in the proxy voting process is exercising our right and responsibility as shareholders of a company.

We welcome the opportunity to comment on the ongoing process at the U.S. Securities and Exchange Commission (SEC) on considering updates to current rules related to shareholder proposals and proxy advisers.  We encourage the Commission to resist pressure to modify the current ownership requirements, resubmission thresholds, and the regulations for proxy advisory firms. The shareholder proposal process is critical to the functioning of the investment intermediation chain. Boston Common Asset Management believes that the current ownership requirements and resubmission thresholds are set at the appropriate levels and should not be changed.

In conclusion, the existing process allows shareholders to engage on issues that affect their portfolio and potentially the company’s reputation. Changes to the current process recommended by some issuers would make it harder for investors to engage with issuers on important ESG matters and access and receive impartial advice necessary to participate in the proxy process.

On behalf of Boston Common Asset Management, we encourage the Commission to refrain from changing existing rules related to shareholder proposals and proxy advisor regulation.

Read the Letter to the SEC here

For more information, please feel free to contact Lauren Compere, Managing Director at

Published On: June 6, 2019Categories: From the Commons