Description: Request for no-action response from SEC regarding shareholder proposal asking Apple to produce a report assessing the climate benefits and feasibility of adopting requirements that all retail locations implement a policy to keep store doors closed.
Rule 14a-8 No-Action Request from Apple, Inc. Regarding Shareholder Proposal of Sustainvest Asset Management, LLC
Filing Date Type File Action Taken Summary 12/12/2017 Letter Download Letter sent by SEC indicating counsel's office would not recommend enforcement action. SEC Said Apple Could Omit Climate Change-Related Shareholder Proposal from Proxy Materials. The U.S. Securities and Exchange Commission (SEC) sent a letter to Apple, Inc. indicating that the SEC’s Office of Chief Counsel would not recommend enforcement action if Apple omitted from its proxy materials a shareholder proposal asking Apple to produce a report assessing the climate benefits and feasibility of adopting requirements that all retail locations implement a policy to keep store doors closed when climate control, especially air-conditioning, was in use. The SEC said there “appear[ed] to be some basis” for Apple’s view that it could exclude the proposal because it had already substantially implemented the proposal. The SEC did not find it necessary to address Apple’s second basis for omitting the proposal—that the proposal concerned Apple’s ordinary business operations.