SEC, NYSE and Nasdaq require companies to provide a means for shareholders and other interested parties to communicate with directors

SEC requires proxy statement disclosure about methods adopted by company to enable direct shareholder communication with directors

• Some disclosures can be made using a company website
• NYSE has a similar - but substantive - requirement in its
  Rule 303A.03 commentary

• NASDAQ has no express requirement
• Audit committees must have means for handling complaints

Required by S-K 407(f)

• Replaces Schedule 14A Item 7(h)
• See S-K 407(f)

NYSE 303A.03 Commentary

Must provide method to receive communications from interested parties

Can be same process used for audit committee
per Rule 10A-3(b)(3)

Audit committee to have means for handling complaints

• per Exchange Act § 10A(m)(4) and Rule 10A-3(b)(3)
• formal procedures for receiving and handling "whistleblowing" complaints from employees and others
• "to alert the audit committee to potential problems before they have serious consequences"
• audit committee to establish procedures that work best for its company
• implemented through SRO listing standards

See Audit committees: Rule 10A-3(b)(3)

Citigroup

• 2005 proxy statement

Citigroup

• 2005 proxy statement

Coca-Cola

• 2005 proxy statement
• Webpage

Exxon Mobil

• 2005 proxy statement
• Webpage

General Electric

• 2005 proxy statement

Google

• 2005 proxy statement
• Webpage

Hewlett-Packard

• 2005 proxy statement
• Webpage

JP Morgan Chase

• 2005 proxy statement
• Webpage

Merck

• 2005 proxy statement
• Webpage

Time Warner

• 2005 proxy statement
• Webpage

Walt Disney Company

• 2005 proxy statement

Corporate Governance

Company Websites