Public companies may ask the Securities and Exchange Commission (SEC) for permission to omit shareholder proposals from their proxy votes through a no- action letter request under Rule 14a-8. This report analyzes the SEC’s responses to these requests from January 1, 2018 through June 15, 2018.

Our CompanyIQ^® analysis of the 222 no-action letters issued the SEC from January 1, 2018 through June 15, 2018 found that:

• Half were approved.
• A third were denied.
• Proxy access made up a significant portion of no-action requests.
• The ordinary business operation justification under 14a(8)(i)(7) was hugely successful.
• Drug pricing is considered a significant ESG policy issue by SEC staff.