We are writing on behalf of the Shareholder Rights Committee of the International Corporate Governance Network (ICGN), which as you know is a global membership organisation of institutional and private investors, corporations and advisors. Our membership spans over 40 countries and the investor members represent capital under management in excess of US $10 trillion. The aim of the ICGN is to contribute to raising standards of corporate governance through the exchange of ideas and information across borders and the development of best practices. Accordingly, we thank the Financial Reporting Council (FRC) for the opportunity to submit comments to its review of the impact of the Combined Code.
We would agree with the findings of your meetings, namely that the Code is working reasonably well but that there is room for improvement on the part of both investors and companies to ensure that its guidance is applied usefully and pragmatically. It is our view that this is more likely to be achieved through continued improvement in practices rather than changes to the Code itself.
See full Letter.
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