On July 2, 2018, the SEC brought a settled cease-and-desist proceeding against The Dow Chemical Company for failing to disclose approximately $3 million in executive perquisites, including personal use of company aircraft, in its proxy statements over five years. The SEC concluded that Dow failed to adequately train key employees to ensure that the proper standard for perquisite disclosures was being applied and that Dow had inadequate processes and procedures to ensure proper reporting of perquisites.… More
Tag Archives: proxy statements
Return to Sender—No Need to Mail Your Glossy Annual Report to the SEC This Year
The Staff has confirmed that the (often forgotten) requirement that public companies mail seven copies of their glossy annual report to the SEC may be satisfied by posting an electronic version of the report on the company’s corporate website. The report must remain accessible for at least one year after posting.
Public companies are already required to post proxy materials, which include proxy statements on Schedule 14A,… More