On 11 May 2023, ICEV issued a letter to S&P Dow Jones Indices (SPDJI).
The letter relates to SPDJI's decision to re-open the S&P Composite 1500 to companies with multiple-class share structures (MCSS).
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ICEV letter to SPDJI
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The ICEV Steering Group is the governing body of ICEV. It is responsible for making strategic decisions regarding, and oversight of, the Coalition’s activities. Asset owner members of ICEV are eligible to apply to join the Steering Group, membership of which is decided by a simple majority of existing ICEV asset owner members. ICEV’s chair is responsible for the overall management of the coalition, which includes leading the assessment of potential engagement targets, fielding ICEV member input, scheduling meetings, initiating discussion during engagements and leading on external communications. ICEV’s vice chair is responsible for ICEV member growth and retention, and for the continuity of scheduled activity in the event of the chair’s absence. ICEV members actively help the chair identify prospective engagement partners as well participate in engagements themselves, should they wish to. ICEV members may abstain from participating in any ICEV letter or engagement for any reason.
In line with ICEV’s Antitrust policy, the responsibility lies with each of the individual ICEV members to understand and adhere to all laws and regulations applicable to them. This includes, but is not limited to, relevant antitrust and competition laws. ICEV members explicitly avoid coordinating on company-specific investment decisions, meeting-specific proxy voting decisions or any other business-related decisions. ICEV’s members are responsible for their own investment, voting and business decisions and must always act completely independently to set their own strategies, policies and practices based on their own best interests. ICEV facilitates the exchange of public information, but members must avoid the exchange (including one-way disclosure) of non-public, competitively sensitive information, including with other members and participants in engagements.
The ICEV Steering Group is the governing body of ICEV. It is responsible for making strategic decisions regarding, and oversight of, the Coalition’s activities. Asset owner members of ICEV are eligible to apply to join the Steering Group, membership of which is decided by a simple majority of existing ICEV asset owner members. ICEV’s chair is responsible for the overall management of the coalition, which includes leading the assessment of potential engagement targets, fielding ICEV member input, scheduling meetings, initiating discussion during engagements and leading on external communications. ICEV’s vice chair is responsible for ICEV member growth and retention, and for the continuity of scheduled activity in the event of the chair’s absence. ICEV members actively help the chair identify prospective engagement partners as well participate in engagements themselves, should they wish to. ICEV members may abstain from participating in any ICEV letter or engagement for any reason.
In line with ICEV’s Antitrust policy, the responsibility lies with each of the individual ICEV members to understand and adhere to all laws and regulations applicable to them. This includes, but is not limited to, relevant antitrust and competition laws. ICEV members explicitly avoid coordinating on company-specific investment decisions, meeting-specific proxy voting decisions or any other business-related decisions. ICEV’s members are responsible for their own investment, voting and business decisions and must always act completely independently to set their own strategies, policies and practices based on their own best interests. ICEV facilitates the exchange of public information, but members must avoid the exchange (including one-way disclosure) of non-public, competitively sensitive information, including with other members and participants in engagements.