Letters

ICGN is an active advocate for corporate governance reform worldwide and regularly responds to public consultations on a range of issues.

Letters Archive

Search to view letters from individual Policy Committees and see the archive list for submissions from the previous years.

Back to Policy Overview

Networks Overview

Policy Committees

Latest outputs

US - SEC: Climate Change Disclosure

20 June 2022

ICGN and GISD Alliance launch newly updated Model Mandate guidance

16 June 2022

US - SEC : (SPAC) Special Purpose Acquisition Companies, Shell Companies, and Projections

13 June 2022

ICGN partners with ecoDa to provide a specific module in its European Board Diploma

9 June 2022

New Zealand - MOBIE: Legislative Response to Modern Slavery and Worker Exploitation Towards Freedom, Fairness and Dignity in Operations and Supply Chains

6 June 2022

EU - ICGN responds to the EU consultation on Corporate Sustainability Due Diligence

23 May 2022

Japan FSA - ICGN Response to Interim Review Following the 2021 Revision of the Corporate Governance Code

16 May 2022

EU Netherlands: Consultation Document: Proposal to Update the Dutch Corporate Governance Code

19 April 2022

US SEC: Amendments to Form PF to Require Current Reporting and Amend Reporting Requirements

21 March 2022

Global Governance

ICGN Global Governance Committee, focused on board leadership, fiduciary duties, independence, culture, committee effectiveness, strategy, risk and remuneration.

Japan: FSA - Council of Experts for the Follow-up of Japan's Stewardship Code and Japan's Corporate Governance Code (inc. Japanese Translation), Dec 2020

Global Governance, Global Governance Principles, Japan

Download

Japan: FSA - Statement to the Council of Experts for the Follow-up of Japan's Stewardship Code and Japan's Corporate Governance Code, Jan 2021

Japan, Global Governance, Global Stewardship

Download

Japan: FSA - Statement to the Council of Experts for the Follow-up of Japan's Stewardship Code and Japan's Corporate Governance Code, Feb 2021

Japan, Global Governance, Global Stewardship

Download

Europe: EU - Sustainable Governance EU Consultation, Feb 2021

Sustainability, Task Force on Climate-related Financial Disclosure (TCFD), Governance, Stewardship and Sustainability, USA

Download

Japan: FSA - Revisions to Japan’s Corporate Governance Code and the Guidelines for Investor and Company Engagement, March 2021

Japan, Global Governance, Guidance

Download

Japan: FSA - Final Comments on Japan's Corporate Governance Code, March 2021

Japan, Global Governance

Download

EU: EU Commission - Targeted Listings Act for SMEs, February 2022

EU, Global Governance

Download

Germany: Regierungskommission - ICGN's Comments on Proposed Changes to the German Corporate Governance Code, March 2022

Government, Corporate Governance, Global Governance

Download

german flag outside parliament buildling

EU Netherlands: Consultation Document: Proposal to Update the Dutch Corporate Governance Code, April 2022

Corporate Governance, EU, Global Governance, Government

Download

Japan FSA - ICGN Response to Interim Review Following the 2021 Revision of the Corporate Governance Code, May 2022

Corporate Governance, Japan

Download

EU - EU Commission: Corporate Sustainability Due Diligence, June 2022

Sustainability, Corporate Reporting

Download

Back to top of the page

Global Stewardship

ICGN Global Stewardship Committee, focuses on fiduciary duties, shareholder rights, shareholder meetings, company monitoring, voting engagement and investment mandates.

Japan : Ministry of Finance on the Amendment bill of the Foreign Exchange and Foreign Trade Act — Regarding Overseas Shareholder rights, February 2020

Shareholder Rights, Japan

Download

South Africa: CRISA - Consultation Paper on Revisions to the Code for Responsible Investing in South Africa, January 2021

Shareholder Responsibilities, Investor Stewardship, Investors, South Africa

Download

Australia: Australian Treasury’s Consultation Paper: Transparency of Proxy Advice, June 2021

Proxy, Disclosure and Transparency, Australia

Download

US: SEC Re: Reopening of Comment Period for Pay Versus Performance, March 2022

Download

US SEC: Amendments to Form PF Requirements for Large Private Equity Advisers and Large Liquidity Fund Advisers, March 2022

Global Stewardship, Risk Oversight, Systemic Risk

Download

Back to top of the page

Financial Capital

ICGN Financial Capital Committee focused on corporate reporting (financial & sustainability), materiality, capital allocation, accounting and auditing standards, risk, internal controls internal, audit, audit committees, and external audit.

Australia: Australian Senate Standing Committees on Economics- responding to the Consultation by the Senate Standing Committees on Economics with regard to Treasury Laws Amendment (2021 Measures No.1) Bill 2021, March 2021

Australia, Government, Global Governance

Download

USA: SEC - Response to the Securities and Exchange Commission on Universal Proxy, June 2021

SEC, Proxy, USA

Download

US: SEC - Proxy Voting Advice Comment Letter, December 2021

Proxy, Voting, Fiduciary Duties, SEC, USA

Download

EU: European Commission - Strengthening of The Quality Of Corporate Reporting, February 2022

Download

US SEC: Share Repurchase Disclosure Modernization, March 2022

Download

US SEC: Proposed Rule 10b5-1 and Insider Trading, March 2022

Download

US - SEC : (SPAC) Special Purpose Acquisition Companies, Shell Companies, and Projections

Download

Back to top of the page

Natural Capital

ICGN Natural Capital Committee focused on governance relating to the natural environment, ecology and biodiversity including climate change and the UN SDGs.

UK: BEIS - Mandating Climate-related Financial Disclosures by publicly quoted Companies, large private Companies and LLPs, May 2021

ESG Reporting, Reporting, Disclosure, Disclosure and Transparency, UK

Download

Canada: CSA Climate Disclosure Reporting, January 2022

ESG Reporting, Climate Change, Reporting, Canada

Download

US - SEC: Climate Change Disclosure, June 2022

Download

Back to top of the page

Human Capital

ICGN Human Capital Committee focuses on anti-corruption, culture, stakeholder relations, workforce engagement, succession planning, diversity-equity-inclusion, human rights, workforce safety and more.