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In many ways, the 2024 proxy season was a continuation of the 2023 season: shareholder proposal volume continued its upward trajectory (in the Russell 3000, shareholders filed 918 proposals in the first half of 2024, compared to 836 during the same period in 2023), while average support for these proposals dipped once more (from 23% in 2023 to 22% in 2024).
However, unlike 2023, which saw support decline across all categories (governance, environmental, social, human capital management (HCM), and executive compensation), the 2024 season witnessed a significant rise in average support for governance proposals (29% in 2023 to 39% in 2024). This jump is primarily driven by the successful passage of proposals seeking to eliminate the supermajority voting requirement (in 2024, the 43 proposals that were voted on received 70% average support, with 31 passing).
The SEC’s no-action request statistics also saw the reversal of a downward trend: in the 2024 proxy season, companies submitted 251 no-action requests—a 50% jump compared with the 2023 season (167 requests). Moreover, this year, the SEC granted a majority (55%) of those requests (versus 45% in 2023) and rejected only 24% (versus 37% in 2023), suggesting a shift in its approach towards shareholder proposals.
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