New on this Page: See our latest advocacy papers from 2015 under "Statements and Submissions". See also a summary report of our last conference from November 2015 in Malaysia.
- Regional Surveys and Reports
- CG Watch
- Conference Reports
- Topic Profiles
- Asian Proxy Voting Survey
- Advocacy Papers
- Country White Papers
- Statements and Submissions
1. Regional Surveys
"CG Watch" is an original regional survey undertaken every two years by ACGA in collaboration with CLSA, one of our founding sponsors. The report looks at macro corporate governance quality in 11 Asian markets and provides aggregate data on more than 900 companies. ACGA undertakes the market analysis while CLSA is responsible for the company survey. The full report is available only to ACGA members and can be downloaded from the Premium Content page. Non-members may purchase the report by contacting Vanessa Chan at: email@example.com.
CG Watch 2014: Dark Shades of Grey
Our seventh survey, published in September 2014, brought further changes in market rankings. We generally found more cause for optimism among the middle-ranked markets, namely Japan, Thailand, Malaysia, Taiwan and India, than either the top- or bottom-ranked markets. Hong Kong and Singapore ranked equal first again, but on lower scores, with each underperforming in critical areas. Continuing underperformance was also apparent among the bottom four, especially Korea, China and the Philippines. Indonesia was an exception, however, and showed improvement. Please see an extract of our market rankings.
CG Watch 2012: Tremors and Cracks
Our sixth survey, published in September 2012, found that on balance, the systemic changes in corporate governance in Asia over the past two years are more positive than negative, reflected in the fact that seven of 11 markets increased in score in 2012 compared to 2010although three of these countries are at the same or a slightly lower level than in our 2007 survey. The main findings included: rising markets were mostly in Southeast and South Asia; North Asia mostly underperformed; Hong Kong rose slightly, but remained second in the rankings after Singapore; Korea rebounded from a low base; and Indonesia slipped back (again) to the bottom of the survey. Please see an extract of our market rankings.
CG Watch 2010: Stray not into perdition
Our fifth survey, published in September 2010. It significantly reordered the ranking of Asian markets in terms of overall CG quality, with Singapore regaining the top spot, Thailand winning the prize for "most improved" and Japan's score improving. India fell markedly in the ranking, while Korea collapsed and the Philippines came last. Indonesia moved into second last for the first time. An extract of the report may be downloaded by all users.
CG Watch 2007: On a wing and a prayer
Our fourth survey, published in September 2007, was the first to incorporate Japan. We expanded the survey, tightened the scoring and focussed more closely on how corporate governance rules and best practices were being implemented by companies. The survey included 87 questions under five categories: "CG Rules and Practices", "Enforcement", "Political and Regulatory Environment", "Accounting and Auditing Standards", and "CG Culture". An extract of the report may be downloaded by all users.
CG Watch 2005: The Holy Grail
Our third survey, published in November 2005. This survey took a different approach to assessing each markets corporate governance rules and regulations: whereas in the past we had scored countries purely on whether a rule existed on paper, this survey looked at the extent to which those rules were being implemented. This approach produced a better approximation of reality, while also being fair to markets and companies. An extract of the report may be downloaded by all users.
CG Watch 2004: Spreading the word
Our second survey, published in September 2004, was the first to include a detailed template of questions developed by ACGA on the macro quality of corporate governance in different markets. An extract of the report may be downloaded by all users.
CG Watch 2003: Fakin' it: Board Games in Asia
Our first survey (and the fourth by CLSA) was published in May 2003. An executive summary of the report may be downloaded by all users.
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ACGA 2015 Conference Report
ACGAs 15th Annual Conference, the Asian Business Dialogue on Corporate Governance 2015, took place in Kuala Lumpur, Malaysia over November 3-4, 2015. The conference programme comprised topical discussion and debate on issues of corporate governance and responsible investment in Southeast Asia, including: board dynamics and dysfunctionality; the role of the chairman; regulatory challenges in Asean; shareholder stewardship and engagement in Asia; and the governance of palm oil, among other topics. We also had a lively debate on the question, Is market quality a drag on corporate governance? See our summary report of the conference.
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ACGA Paper on Independent Directors in Asia, August 2010
While working on "CG Watch 2010", we compiled a paper outlining the different requirements in Asia for independent directors on company boards.
Over the past few years, a number of markets such as Thailand, Taiwan, Philippines and Korea have been amending their regulations and Codes of Corporate Governance leading to more transparent, and in some cases stricter, rules on the number of independent directors on boards. Also of note is the fact that in some jurisdictions, such as Singapore, Malaysia and Korea, banking acts set more stringent rules on the board composition of banks. Meanwhile, some markets require supervisors as well as independent directors (a legacy of their company law being based on German civil law).
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Asian Proxy Voting Survey
ACGA Asian Proxy Voting Survey, September 2006
In mid-September 2006, ACGA published its inaugural report on proxy voting systems in Asia. Titled, "Voting for Change: Bringing Proxy Voting Systems in Asia into the 21st Century", the report examines the many impediments to effective and efficient voting in the region and makes a series of practical recommendations for companies, investors, regulators and custodians to implement.
The report also includes a detailed survey of the voting experiences of major institutional investors in 11 Asian markets and three benchmark economies--Australia, the UK and the US. It finds Hong Kong the clear leader in Asia, but well behind the benchmark markets.
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2. Advocacy Papers
Country White Papers
Taiwan White Paper, February 2011
On February 24, ACGA launched a new policy paper on Taiwan, the "ACGA White Paper on Corporate Governance in Taiwan". The Chinese version of the paper can be downloaded here.
The "Taiwan White Paper", the third policy paper we have done on an individual market, was compiled by ACGA on the basis of our own research and numerous contributions from ACGA members and associates around the world and in Taiwan. The paper is the first effort of its kind focussing on corporate governance issues in Taiwan and makes a series of recommendations for reform in three key areas:
- Shareholder meetings and voting;
- Board effectiveness; and
- Shareholder rights.
We believe that if Taiwan brings its corporate governance regime more closely into line with global best practices, this would help to attract more investment and make its capital markets more internationally competitive.
Our hope is that the points and recommendations raised in this document will serve to stimulate a lively exchange of views among and between government officials, legislators, financial regulators, stock exchanges, listed companies, as well as both domestic and foreign investors in Taiwan.
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India White Paper, January 2010
On January 19, 2010, ACGA launched a new policy document on India, the "ACGA White Paper on Corporate Governance in India".
The "India White Paper" was compiled with the support and input of ACGA members and friends in India and around the globe, and is the first effort of its kind focussing on corporate governance issues in India. The paper makes a series of recommendations for reform in five key areas:
- Shareholder meetings and voting;
- Related-party transactions;
- Preferential warrants;
- Corporate disclosure; and
- The auditing profession.
ACGA believes these reforms are necessary to strengthen the long-term competitiveness of India's capital markets and the accountability of its listed companies.
Prior to and after the launch, we talked to a number of regulators, fund managers, analysts, government officials and business federations about the White Paper, including: the National Stock Exchange; the Securities and Exchange Board of India (SEBI); Ministry of Finance; Institute of Company Secretaries of India; Ministry of Corporate Affairs; and the Federation of Indian Chambers of Commerce and Industry.
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Japan White Paper, May 2008
On May 15, 2008, the "White Paper on Corporate Governance in Japan", a new policy document on corporate governance in Japan published by ACGA, was launched. The Japanese version of the paper can be downloaded here.
The Japan White Paper is the first collaborative effort of its kind focussing on corporate governance issues in Japan and involving global institutional investors. The paper states that sound corporate governance is essential to building a more internationally competitive corporate sector in Japan and to the longer-term growth of the Japanese economy and its capital markets. It argues that while a number of leading Japanese companies have improved their corporate governance practices in recent years, the system of governance in most Japanese listed companies fail to meet the needs of stakeholders or the nation in three ways:
- By not providing for adequate supervision of corporate strategy;
- By protecting management from the discipline of the market, thus rendering the development of a healthy and efficient market in corporate control all but impossible;
- By failing to provide the returns that are vitally necessary to protect Japan's social safety netits pension system.
Accordingly, the White Paper makes recommendations on six key issues:
- Recognition of shareholders as owners of listed companies
- Efficient use of capital
- Independent supervision of management
- Pre-emption rights and third-party share placements
- Poison pill takeover defences
- Fairness and transparency in shareholder voting
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Statements and Submissions
Hong Kong Enhanced ESG Reporting Guide
On December 21, 2015, Hong Kong Exchanges and Clearing (HKEx) published a conclusions paper on a consultation it carried out on upgrading its ESG Reporting Guide from a voluntary to a comply or explain document. ACGA sent in a submission to HKEx in late September 2015. See our highlights of the enhanced Guide.
Implementation of Japan CG and Stewardship Codes
On December 17, 2015, ACGA wrote to the Financial Services Agency (FSA) of Japan to comment on issues to be discussed in meetings of its "Council of Experts Concerning the Follow-up to the Japan Stewardship and Corporate Governance Codes". The FSA recently formed the Council to review progress in the implementation of the two Codes.
Our letter contains nine sections and covers issues such as avoiding boilerplate disclosure;
the strategic role of the board; board evaluation; and cross-shareholdings. See our letter to the FSA.
Hong Kong Principles of Responsible Ownership
On June 16, 2015, ACGA responded to a consultation conducted by the Hong Kong Securities and Futures Commission (SFC) on a proposed Principles of Responsible Ownership (ie, stewardship code). See our submission to the SFC.
TSE Listing Rule Amendments
On March 26, 2015, ACGA wrote to the Tokyo Stock Exchange (TSE) on a consultation it carried out on the development of its Listing Rules for the implementation of the Japan Corporate Governance Code. See our letter to the TSE.
Consultation on Japan CG Code
On January 28, 2015, ACGA submitted comments to the Financial Services Agency (FSA) of Japan on its draft Corporate Governance Code. ACGA welcomes the Code, which is due to take effect in June 2015, and believes it will lead to progress in many areas of Japanese corporate governance. See our letter to the FSA.
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METI Study Group on AGMs
On December 12, 2014, ACGA wrote to the Ministry of Economy, Trade and Industry (METI) on the subject of Japanese AGMs. METI formed a study group on improving the processes around AGMs and sought ACGA's views on the challenges that global investors face when voting shares in Japan. See our letter to METI.
Letter to Hong Kong Chief Executive
On November 28, 2014, ACGA Chairman, Douglas Henck, wrote the Chief Executive of Hong Kong, Mr. C.Y Leung, on enhancing Hong Kongs status as an international financial centre. The letter made recommendations on three issues: developing a long-term strategy on corporate governance for Hong Kong; introducing an independent audit regulatory body as soon as possible; and not introducing dual-class shares. See our letter to Mr. Leung.
Dual-class Shares in Hong Kong
On November 28, 2014, ACGA responded to a concept paper from Hong Kong Exchanges and Clearing (HKEx) on "weighted voting rights" (ie, dual-class shares). We oppose the introduction of such shares on the grounds of fairness and good governance, long-term market valuation, and the operation of the Hong Kong Takeovers Code, among other factors. See our letter to HKEx.
Preliminary Recommendations on Japan CG Code
On November 25, 2014, ACGA wrote to the Financial Services Agency (FSA) of Japan with a series of preliminary recommendations for the country's forthcoming Corporate Governance Code. Our comments covered issues such as the operation of the "comply or explain" principle, the need for some degree of practical guidance to issuers on governance best practices (ie, the Code should not just be a set of principles), and the need for the Code to address local issues in Japan, among other things. See our letter to the FSA.
ACGA Survey on Alibaba
On Tuesday, April 15, 2014, ACGA held a press conference to release its "Survey on Alibaba and Non-Standard Shareholding Structures in Hong Kong". The survey asked global and regional institutional investors a series of questions on the dual-class share issue, their views on the special partnership structure sought by Alibaba in its earlier proposed Hong Kong listing, and whether they would discount both Alibaba and the Hong Kong market if non-standard shareholding structures (NSSS) became common.
Survey respondents included 54 of ACGA's institutional investor members with combined assets under management globally of more than US$14 trillion. The main findings were:
- Overwhelming opposition to dual classes of shares and the proposed Alibaba partnership structure.
- Investors would likely apply a significant discount (average of 19%) to Alibaba if it listed with its special partnership structure.
- Investors would also likely apply a significant discount to the Hong Kong market (average of more than 13%) if non-standard shareholding structures became common.
- Allowing corporate governance exemptions under the Listing Rules for so-called innovative companies would set a bad precedent and undermine investor protection.
Unaudited Financial Reports in Korea
In early March 2014, ACGA, in conjunction with APG Asset Management Asia and more than 30 of our members, wrote to 26 of the largest listed companies in Korea on the issue of unaudited annual accounts being sent to shareholders prior to AGMs. Global investors are effectively forced to vote on these unaudited accounts because, under Korean company law, final audited financials only need to be published seven days before the annual meeting. In practical terms, this falls after the voting deadlines that foreign shareholders must meet. See a template of our letter (without signatures).
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"The Roles and Functions of Kansayaku Boards Compared to Audit Committees"
On October 31, 2013, ACGA published an original paper outlining the history and function of the Kansayaku Board system in Japan and comparing it to the standard model Audit Committee system found in most other developed markets. While we recognise that the Kansayaku system has certain strengths, our conclusion is that the Audit Committee system offers a significantly stronger mechanism for supervision of internal controls over financial reporting and related risk management. Our paper is available in both English and Japanese.
Letter to SCMP on Alibaba
On September 16, 2013, the South China Morning Post newspaper published a letter from ACGA opposing a proposal to reintroduce dual-class shares in Hong Kong and allow Alibaba to list with a special partnership structure. See our letter to the SCMP.
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Submission to HKEx Board Diversity consultation
On November 9, 2012, ACGA sent our final submission to the Hong Kong Exchanges and Clearing (HKEx) on its "Consultation Paper on Board Diversity". The Exchange was looking for feedback on promoting board diversity and amending the Corporate Governance Code in order to do that.
Submission to IAASB Invitation to Comment: Improving the Auditor's Report
On October 13, 2012, ACGA sent our response to the June 2012 Invitation to Comment: Improving the Auditor's Report from the International Auditing and Assurance Standards Board (IAASB). ACGA limited its response to a few issues: how an expanded, amended auditor report that included an Auditor Commentary could be used as a handy guide on how to read complex accounts; that the Board should more thoroughly review the issue of "going concern" and "material uncertainty" before finalising any changes in the standards; and a few suggestions on how to make the auditor report more transparent.
Submission on IPO Sponsor Regulation in Hong Kong
On July 6, 2012, ACGA sent our final submission to the Hong Kong Securities and Futures Commission (SFC) on its "Consultation Paper on the Regulation of Sponsors". The aim of this consultation is to improve the quality of due diligence carried out by investment-bank "sponsors" for IPOs in Hong Kong and enhance the value of prospectuses.
We broadly supported the SFCs proposals in our submission, but believe much more emphasis should be placed on the governance advisory role of sponsors in helping listing applicants implement basic systems of governance well before their IPO. We recommended some tangible criteria that the regulator could use to assess the extent and depth of pre-IPO governance preparation. We also expressed concerns about the structure of fees for sponsoring compared to underwriting and the potentially adverse effects on due diligence caused by the proclivity for multiple sponsors and multiple bookrunners (leading to the fee pie being shared between ever larger numbers of banks).
Submission to MOJ consultation on Companies Act proposal
On January 31, 2012, ACGA submitted its response to the Ministry of Justice's "Interim Proposal concerning Revision of Companies Act". ACGA limited its comments to the proposals to strengthen the independence of Outside Directors and obligate public and listed companies to appoint such Outside Directors. A Japanese translation of the submission was also provided to the MOJ.
Statement on third-party allotments in Japan
On January 19, 2012, ACGA released a statement to the media on the weaknesses in the Japanese financial regulatory system in regulating third-party allotments (third-party placements) and their potential adverse impact on minority shareholders. A Japanese translation of the statement was also provided to the media.
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Submission to Securities Commission Malaysia
On December 12, 2011, ACGA submitted a response to the SC's CG Blueprint, which it released in July 2011, and a November Consultation on Independent Chairman and Voting by Poll.
ACGA analysed and made recommendations on most of the key proposals, including:
- Voting by poll;
- Appointment of proxies and corporate representatives;
- A new code and industry umbrella body for institutional investors;
- Mandating nomination committees;
- Limiting the number of directorships; and
- Independent chairmen.
While we supported many of the proposed revisions, we did suggest amendments to some.
Letter to Tokyo Stock Exchange
On November 17, 2011, ACGA wrote a letter to the Tokyo Stock Exchange (TSE) regarding the Olympus Corporation and its ongoing status as a listed company. A Japanese translation of the letter can be found here. Our main points were:
- That the Exchange should refrain from delisting the company even if it meets the December 14 deadline for its quarterly report;
- That delisting is generally not a favourable penalty for securities malfeasance since it punishes shareholders as much as the managers responsible; and
- Olympus would probably not be delisted in most other developed market exchanges since it remains a going concern with a reasonable business.
The letter was co-signed by 16 members of ACGA who hold approximately 17% in aggregate of the issued share capital of Olympus.
Submission to Ministry of Finance, Singapore
On September 30, 2011, ACGA submitted a response to a Ministry of Finance consultation paper on the Report of the Steering Committee for Review of the Companies Act.
ACGA analysed and made recommendations on selected issues, including:
- The disclosure requirements under sections 156 and 165 should be extended to the Chief Executive Officer of a company;
- To allow for multiple proxies to be appointed to AGMs;
- To allow the multiple proxies to vote on a show of hands at shareholders' meetings;
- To amend the timeline for the filing of proxies from 48 hours prior to the shareholders' meeting to 72 hours prior to the shareholders' meeting;
- Liberalise rules on electronic transmission of notices and documents; and
- Companies should be allowed to issue non-voting shares and shares with multiple votes.
While we supported most of these proposals, we did suggest amendments to some, and strongly opposed allowing companies to issue non-voting shares and shares with multiple votes.
Submission to Monetary Authority of Singapore
On August 3, 2011, ACGA submitted a response to a Monetary Authority of Singapore consultation paper on proposed revisions to the Singapore Code of Corporate Governance.
ACGA analysed and made recommendations on most of the key proposals, including:
- Director Independence;
- Board Composition;
- Director Training;
- Multiple Directorships;
- Remuneration Practices and Disclosure;
- Risk Management; and
- Shareholder Rights and Role.
While we supported many of the proposed revisions, we suggested amendments to several and sought clarification on some of the issues raised.
Letter on Capital Raising in Japan
On June 25, 2011, ACGA wrote to the Financial Services Agency (FSA) of Japan on the issue of capital raising. Our letter addressed ongoing weaknesses in the country's system of public offerings, rights issues and private placements, and made a series of recommendations for improving efficiency and investor protection.
Submission to Singapore Exchange, June 2011
On June 13, 2011, ACGA submitted a response to a Singapore Exchange consultation paper on proposed rule changes on general meetings to increase shareholder engagement and introduce voting by poll.
ACGA analysed and offered responses on all four proposals:
- Issuers with primary listings in Singapore should be required to hold shareholder meetings there;
- Listed companies should be required to vote by poll on all resolutions at all general meetings;
- Issuers shall announce immediately after each general meeting the outcome of the voting; and
- Amending the relevant Catalist Rules arising from the above proposals.
We supported all the above proposals with the exception of providing a grace period for smaller issuers until January 1, 2014.
ACGA Letter on India Proxy Proposal
On May 27, 2011, ACGA wrote letters opposing a recommendation by the Indian parliament's Standing Committee on Finance to remove the right of shareholders to appoint proxies. The proposal was made in a report that was given to the parliament in August 2010. The letters were addressed to Dr. K. P. Krishnan, Secretary, Economic Advisory Council to the Prime Minister, and Shri D. K. Mittal, Secretary, Ministry of Corporate Affairs. We also sent a copy to the Securities and Exchange Board of India.
The Committee argued that since postal ballots were already in use and electronic voting was being introduced in the new Companies Bill, "the need for proxies may
become minimal". In our letter we noted that postal ballots can only be used for certain special resolutions,
such as major transactions; they cannot substitute for ordinary resolutions in an AGM.
Meanwhile, the argument that electronic voting will make proxies obsolete is prematurenot only will the adoption of electronic voting be voluntary on the part of companies, but experience in other markets in Asia (Japan, Taiwan and Korea) indicates that implementing this system takes time and is harder than regulators expect.
Hong Kong CG Code Amendments
In mid-April, 2011, ACGA submitted a response to a Hong Kong Exchanges and Clearing Limited (HKEx) consultation paper, published in December 2010, on proposed changes to the Hong Kong Code on Corporate Governance Practices.
ACGA analysed and made recommendations on nine issues:
- Directors duties and recommendations, including on the number of directorships;
- Director training and independent directors;
- Remuneration and nomination committee;
- Corporate governance committee;
- Audit committee;
- Management accounts;
- Shareholders general meetings;
- Voting by poll; and
- Appointment and removal of auditors.
We agreed with most of the proposals we responded to, although we recommended that some should be reworded or further expanded on.
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Company Law Reform in Japan
On September 28, 2010, ACGA wrote a letter to the Ministry of Justice expressing our views on some amendments, including the general model of governance for corporations, the role and authority of statutory auditors (kansayaku), the proper role of directors, and the governance of dilutive capital issues, to the Company Law that the Legislative Advisory Council's Company Law Sub-Committee was considering.
We provided specific comments and suggestions on:
- Independent directors;
- Board committees;
- Role of boards;
- Voting by Kansayaku;
- Shareholder approval rights: and
- The "Joint Audit Committee Company" proposal.
ACGA Statement on CG Reform in Japan
On December 15, 2009, ACGA released its new "ACGA Statement on Corporate Governance Reform in Japan" in both Japanese and English. A press release was also released to the media. The Statement is a follow-up to the 2008 ACGA "Japan White Paper" and a response to the various corporate governance policy papers produced this year by leading business and government agencies in Japan -- namely, the Nippon Keidanren, Ministry of Economy, Trade and Industry (METI), Financial Services Agency (FSA), and Tokyo Stock Exchange (TSE).
The Statement analyses and offers reform recommendations on five main issues:
- The role of independent directors vis-à-vis statutory auditors (Kansayaku);
- Shareholder meetings and proxy voting;
- Private placements and other capital-raising issues;
- Cross-shareholdings and other equity investments;
- Company-investor dialogue.
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New M&A Rules in Indonesia
On June 24, 2008, ACGA wrote to Bapepam, the capital market supervisory authority in Indonesia, to raise concerns about new M&A rules, in particular a plan to raise the threshold of general offers from 25% (slightly more rigorous than the regional norm of around 30%) to 50% (which would effectively control to change hands without the need for a general offer). See our letter to Bapepam.
Memo on HKEx Listing Rule Consultation
In February 2008, ACGA prepared a memo for members on an omnibus combined consultation published by Hong Kong Exchanges and Clearing (HKEx) the previous month. The consultation sought market views on a wide range of issues, including sponsor independence, minimum public float, pre-vetting of issuer announcements, voting by poll, and the director blackout period, among other things. The consultation also sought views on whether to change the rules on the general mandatea reform that ultimately did not proceed. See our memo.
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Multiple Proxies in Singapore
In October 2007 ACGA submitted an original paper to the Singapore Government titled, Opening Shareholder Meetings to Fund Managers in Singapore. It addresses legal obstacles that stand in the way of institutional investors attending shareholder meetings in Singapore (known as the two proxy card issue). The paper offers recommendations on how to resolve the issue, including amendments to the Companies Act and the Listing Manual of the Singapore Stock Exchange.
Singapore Proxy Voting Roundtable
On January 15, 2007, ACGA co-hosted a Proxy Voting Roundtable in Singapore with the Singapore Association of the Institute of Chartered Secretaries and Administrators (SAICSA) and the Singapore Institute of Directors (SID). The main themes arising from the Roundtable are covered in a summary paper on the event. Key issues included: voting by poll; appointment of multiple proxies to shareholder meetings; clustering of AGM dates; deadlines for holding AGMs after the year end; meeting notice periods; and attendance of CPF members at AGMs. The programme for the event, including details on speakers and other supporting organisations, is attached. See also ACGA's presentation to the Roundtable.
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Memo on Hong Kong General Mandate
ACGA prepared a memo for members comparing the rules on general mandates (private placements) in Hong Kong with those in the UK. We also looked at voting practices in Hong Kong on this issuecharacterised by minority shareholders voting against in large numbersand some recent corporate decisions to remove or reduce the mandate. See our memo.
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Hong Kong General Mandate 2
On December 20, 2004, ACGA wrote again to Hong Kong Exchanges and Clearing (HKEx) on the issue of general mandates. We expressed support for HKExs plan to remove its general mandate at its 2005 AGM and noted the large votes against such mandates from independent shareholders. See our letter to HKEx.
Hong Kong General Mandate 1
On May 14, 2004, ACGA wrote to Hong Kong Exchanges and Clearing (HKEx) encouraging it to tighten rules further on general mandates (ie, private placements of up to 20% of issued capital and up to a 20% discount). Hong Kongs are relatively lax in this regard. See our letter to HKEx.
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