US Securities and Exchange Commission (SEC) rules for posting proxy materials

Implementation required since 2007

1. Available on the Internet at the time of Notice

   “All proxy materials to be furnished through the notice and access model... must be posted on a specified Internet Web site by the time the issuer sends the Notice to shareholders.”

2. Easy to use online

   “The final rules require the electronically posted proxy materials to be presented on the Internet Web site in a format, or formats, convenient for both printing and viewing online.”

3. Identical to the paper version

   “…the materials should be posted in a format that provides a version of those materials, including all charts, tables, graphics, and similarly formatted information, that is substantially identical to the paper version of the materials.”

4. Searchable

   “...the materials also must be presented in a readily searchable format...”

5. EDGAR version is not enough

   “The Internet Web site that an issuer uses to electronically furnish its proxy materials to shareholders must be a publicly accessible Internet Web site other than the Commission’s EDGAR Web site... simply providing a link to the proxy materials on EDGAR [is] insufficient.”

6. User-friendly navigation features are recommended

   “...user-friendly features such as hyperlinks from a table of contents to enable shareholders to quickly and easily navigate through the document.”

7. Website is confidential

   "An issuer must maintain the Internet Web site on which it posts its proxy materials in a manner that does not infringe on the anonymity of a person accessing that Web site."

   "...a company must refrain from installing cookies and other tracking features on the Web site on which the proxy materials are posted."

Read about these rules on the SEC website with these links:  34-55146 Internet Availability of Proxy Materials  and 34-56135 Shareholder Choice Regarding Proxy Materials.