2011 Proxy Season Preview Key Takeaways In Singapore, a few companies are voting by poll, but the majority still decides general meetings on a show of hands, effectively disenfranchising international investors. Malaysia has moved to close a listing rules loophole, and now requires that companies seeking to take over a listed firm by buying its assets must get approval of at least 75 percent of the target company’s shareholder as opposed to a simple majority, as was previously the requirement. Poor disclosure remains a concern in Indonesia, given weak disclosure requirements. Information on directors is rarely provided, and the elections of directors are typically bundled. The Philippines Stock Exchange launched a new set of Corporate Governance Guidelines on Nov. 26, 2010, with the market also looking to introduce the "Maharlika Board," with a higher set of corporate governance standards. The level of disclosure in Vietnamese annual reports is inadequate, with these reports rarely including a director profile or a separate corporate governance report. Southeast Asia Report Authors Indonesia and Thailand Geraldine Yazon geraldine.yazon@issgovernance.com Victor DyEcho victor.dyecho@issgovernance.com Malaysia Victor DyEcho victor.dyecho@issgovernance.com Khristina De Castro khristina.decastro@issgovernance.com Philippines Neva Arboleda-Santos neva.arboleda@issgovernance.com Singapore Jaja Figueroa jaja.aquas-figueroa@issgovernance.com Vietnam Christina Montemayor christina.montemayor@issgovernance.com Singapore Key Issues Proxy Voting Method Voting by a show of hands continues to be the norm in the market although a few companies have started using poll voting during the 2010 season. Index companies such as Singapore Telecommunications Ltd., Oversea-Chinese Bank Ltd., 2011 Proxy Season Preview: Southeast Asia Singapore Technologies Engineering Ltd., and Neptune Orient Lines Ltd. employed poll voting in 2010, following the likes of Singapore Exchange Ltd. (SGX), Fraser and Neave Ltd., City Developments Ltd., and Noble Group Ltd., which started using the one-share, one-vote system earlier. The introduction of a criterion that a director may not be considered independent after serving on the board for a continuous period of nine years, with effect from the 2012 AGM of each financial institution; An increase in the number of independent directors on the board, nominating committee and remuneration committee from the current one-third to a majority, with effect from the 2012 AGM of each financial institution; Additional guidance to emphasize that the roles and responsibilities of the nonindependent chairman of the board and lead independent director should be properly spelled out so as not to diffuse board leadership; and Additional guidance on the establishment of a dedicated Board Risk Management Committee comprising at least three directors, the majority of whom must be non-executive, with at least two members possessing relevant technical financial sophistication in risk disciplines or business experience. Legislative & Regulatory Developments Equity Fund Raising – Rights Issues In consultation with the Monetary Authority of Singapore (MAS), in January 2009 SGX introduced measures to facilitate equity fund raising by listed companies amidst the global credit crisis. The measures were valid for two years until Dec. 31, 2010. With effect from Jan. 1, 2011, the general mandate given to listed companies limits the issuance of new shares on a pro-rata basis to 50 percent of current outstanding capital, removing the authority to issue up to 100 percent when issuing shares via a renounceable rights issue. In addition, major shareholders are no longer allowed to enter into sub-underwriting arrangements and receive subunderwriting fees to take up their rights entitlements and/or sub-underwrite excess rights shares in connection with a rights issue. Revisions were made following the close of a public consultation in April 2010 in which 20 respondents including 11 financial institutions and Temasek Holdings Pte. Ltd. participated. Revised Corporate Governance Regulations and Guidelines for Financial Institutions Malaysia In December 2010, MAS released revisions to the Banking (Corporate Governance) Regulations 2005 and Insurance (Corporate Governance) Regulations 2005 (collectively referred to as "the Regulations") applicable to all banks, financial holding companies and direct insurers incorporated in Singapore (Financial Institutions) and Guidelines on Corporate Governance (Guidelines) applicable to financial institutions listed in Singapore. Key revisions to the Regulations and Guidelines include: Key Market Characteristics Published March 23, 2011 Key Issues Most companies have boards that are composed of at least one-third independent directors. In addition, they maintain key board committees, such as the audit, remuneration, and nomination committees that are majority independent (save for the audit committee, which should comprise only of non-executive directors). Page 2 © 2011 Institutional Shareholder Services Inc. All rights reserved. The information contained in this report may not be republished, rebroadcast or redistributed without the prior written consent of ISS. 2011 Proxy Season Preview: Southeast Asia According to the Companies Act, 1965, companies should hold their annual general meetings once a year and not more than 15 months from the last annual general meeting; hence, most (AGMs) are held in the month of June given that most of the companies have their financial year-end in December (main proxy season). management board composed of directors who are responsible for the day-to-day management of the company. A small number of companies have their yearend in March, which means they hold their AGMs during the month of September (miniproxy season). Legislative & Regulatory Developments Takeover Rules Recent amendments to the Main Market Listing Requirements provide that companies seeking to take over a listed firm by buying its assets must get the approval of at least 75 percent of the company’s shareholder as opposed to a simple majority vote (50 percent plus one) previously implemented. It is believed that the new rule will ensure that shareholders of listed companies will receive the same degree of protection regardless of the chosen route to privatize a company. Neighboring countries, such as New Zealand, Hong Kong, and Thailand, already apply the 75-percent threshold rule. Indonesia Key Issues Key Market Characteristics Annual general meetings (AGMs) are to be held within a period of up to six months after the financial year-end. Since most financial books of companies close in December, most AGMs are held between January and June of each year with June being the busiest month for AGMs. However, this has not stopped a few companies having the above year-end from holding their AGMs after June. In this case, such companies normally seek shareholder approval for the dispensation on the delay of the AGM. Disclosure Poor disclosure remains a concern in Indonesia due to the weak disclosure requirements implemented by regulatory bodies such as the Bapepam-LK, Indonesia's Capital Market and Financial Institutions Supervisory Agency, and the Indonesian Stock Exchange (IDX). For example, the names and qualifications of director and/or commissioner nominees, which are mostly presented as bundled proposals, are often not disclosed prior to the meeting since this is not required under the law. Only information regarding material and connected transactions and mergers, consolidations, acquisitions or demergers are required to be disclosed to the public. Such disclosure should be released in public newspapers and at the IDX prior to the invitation to the general meeting of shareholders for the transactions. Legislative & Regulatory Developments On the regulatory front, there has been no movement in Calendar 2010. Issuers have a two-tiered board structure, comprising (i) the supervisory board composed of commissioners who are responsible for the oversight of management, and (ii) the Published March 23, 2011 Page 3 © 2011 Institutional Shareholder Services Inc. All rights reserved. The information contained in this report may not be republished, rebroadcast or redistributed without the prior written consent of ISS. 2011 Proxy Season Preview: Southeast Asia Philippines Key Issues The survey also points out the following weaknesses in the country’s corporate governance practices: Codes and Securities Laws in the Philippines are not up to par with international and regional best practices by setting the bar low in areas such as director independence. The Amended Implementing Rules and Regulations of the SEC specify that all listed companies should have at least two independent directors or at least 20 percent of their members but in no case less than two. Presently, Malaysia, Hong Kong, and Singapore require boards of publicly listed to be no less than 33 percent independent. Former executive directors may qualify as independent directors after just a two-year cooling-off period. Regulators such as the SEC are not sufficiently resourced and are generally regarded as “toothless.” Lack of enthusiasm for the Maharlika Board and other Corporate Governance initiatives of the PSE. Removal of Preemptive Rights Some companies are seeking to disenfranchise minority shareholders by amending their bylaws to remove the preemptive rights of their shareholders even if this right is encoded in the Corporations Code of the Philippines. In 2010, Ayala Corporation (AC), International Container Terminal Services, Inc. (ICSTSI) and San Miguel Corporation (SMC) all passed resolutions that effectively denied preemptive rights to their shareholders. Resolutions seeking shareholder approval to deny preemptive rights are almost always done under an amendment of a company’s charter. The Corporations Code of the Philippines allows the denial of preemptive rights for the following circumstances: a. "Shares issued in compliance with laws under stock offerings or minimum stock ownership by the public;" or b. "Shares to be issued in good faith with the approval of the stockholders representing two-thirds of the outstanding capital stock in exchange for property needed for corporate purposes or in payment of previously contracted debt." Credit Lyonnais Securities Asia (CLSA), in collaboration with the Asian Corporate Governance Association (ACGA), released Corporate Governance Watch 2010 in September of last year and highlighted the denial of preemptive rights as one of the key elements why corporate governance practices in the Philippines regressed in 2010. CLSA expressed that corporate governance practice in the Philippines is the “most disappointing” which resulted in the country ranking last in the survey. The report surveyed 580 companies in Asia and 11 countries including Japan. Published March 23, 2011 The survey also notes that the Bangko Sentral ng Pilipinas is “much more professional,” and is an “indication of what effective local regulation can look like.” The report also concluded that “most institutional investors are yet to invest sufficiently in voting, engagement or stewardship.” Legislative & Regulatory Developments New Corporate Governance Guidelines On the heels of the Corporate Governance Watch 2010 Survey of CLSA, the PSE launched a new set of Corporate Governance Guidelines on Nov. 26, 2010. The new set of guidelines is a step toward the creation of the Maharlika Board, which would be the fourth board of the PSE that adheres to a higher set of corporate governance standards. The Page 4 © 2011 Institutional Shareholder Services Inc. All rights reserved. The information contained in this report may not be republished, rebroadcast or redistributed without the prior written consent of ISS. 2011 Proxy Season Preview: Southeast Asia guidelines are implemented on a comply-orexplain regime where companies are required to explain their non-compliance with the guidelines. Listed companies are required to submit a disclosure template provided by the PSE annually starting Jan. 30, 2011. The new guidelines include the following provisions which bring CG practices in the Philippines up to par with its regional counterparts: Boards must now have at least three independent directors or 30 percent of its board, whichever is the higher. The board should now have audit, risk, governance, nomination, and election committees. The audit committee should approve all nonaudit services ensuring that non-audit fees do not exceed the fees earned from external audit. Provision of supermajority or “majority of minority” voting mechanisms to protect minority shareholders against the actions of controlling shareholders. Have at least 30 percent public float to increase liquidity in the market. The current rule on public ownership is 10 percent. Disclosure of director and executive compensation policy. Disclosure of groups or individuals who hold 5 percent or more ownership interest in the company, significant cross-shareholding relationship, and cross guarantees. Disclose the existence of agreements that may impact the control of the company. Define thresholds for related-party transactions, considering the aggregate amount of related-party transactions under a 12-month period as the basis for the threshold Published March 23, 2011 A New Leadership at the PSE Hans Sicat was announced as the new CEO of the PSE in January 2011. His appointment came about after the bourse’s former president, Val Suarez, resigned due to conflict-of-interest issues. Suarez stayed as the president for just five months after the SEC fined the PSE more than Php1 million primarily because Suarez was married to the president and managing director of JP Morgan Securities Philippines, Inc., a trading participant. In an interview, Sicat said the bourse needs to catch up with its peers in the region in terms of liquidity, trading volume, interest and number of products. He also stated his plans of continuing the corporate governance initiatives of the board including the Corporate Governance rule book and the Maharlika Board. The new president also expressed his interest in the creation of new products, including a futures markets and exchange traded funds. Other Capital Market Developments One of the major projects that the bourse is undertaking this year is its link-up with the planned ASEAN Trading Link which is expected to go live by the end of 2011. The regional trading system would initially involve Bursa Malaysia, the PSE, the Singapore Stock Exchange, and the Stock Exchange of Thailand. This project aims to link together these markets thereby facilitating cross border trading. The estimated value of the combined markets is said to be $1.9 trillion and would have the size and capacity to compete with Hong Kong and Tokyo. In October 2010, the bourse published the Listing Rules for Real Estate Investment Trusts (REIT). The SEC approved the adoption of the Implementing Rules and Regulations for REITs on May 13, 2010. The Bangko Sentral ng Pilipinas (BSP) announced earlier this year that stand-alone trust units may now be permitted to operate as part of the efforts to increase the number of players in the local capital market. Trusts have always operated Page 5 © 2011 Institutional Shareholder Services Inc. All rights reserved. The information contained in this report may not be republished, rebroadcast or redistributed without the prior written consent of ISS. 2011 Proxy Season Preview: Southeast Asia as subsidiaries or departments of local banks prior to this ruling. Thailand Board of Management, the Board of Inquiry and General Director. The Model Charter of listed joint stock companies requires one-third of the board to be non-executive directors. However, the concept of non-executive director is still new in Vietnam and the definition of non-executive is not clearly defined by law. Currently, the level of disclosure in annual reports is inadequate. Generally, annual reports do not include a director profile or a separate corporate governance report. Key Issues Key Market Characteristics The Principle of Good Corporate Governance for Listed Companies, 2006 recommends that companies have a minimum of three independent non-executive directors or equivalent to at least one-third of the board size. However, up to this point there is still no law mandating companies to maintain a certain level of board independence. Quite a number of Thai companies are still closely held by controlling families who get involved in management due to cronyism. Annual general meetings are held within four months from the end of the accounting year. Since most Thai companies close their books in December, most AGMs are held from January to April of each year with the latter being the busiest month for AGMs. Legislative & Regulatory Developments On the regulatory front, there has been no movement in Calendar 2010. Vietnam Key Issues Key Market Characteristics The corporate management in listed companies in Vietnam follows a two-tier structure comprising a board of directors known as the Published March 23, 2011 Legislative & Regulatory Developments Vietnam Corporate Governance Project In an effort to improve corporate governance practices in Vietnam, the World Bank's International Finance Corporation (IFC) implemented the Vietnam Corporate Governance Project in October 2008 in partnership with Finland, Ireland, the Netherlands, New Zealand, and Switzerland. As part of this program, IFC published the corporate governance manual and the corporate governance scorecard for Vietnam in cooperation with the country's securities market regulator, the State Securities Commission and Global Corporate Governance Forum on December 8, 2010. The corporate governance manual provides recommendations to shareholders, corporations, and the government for implementation and monitoring of good governance standards. The corporate governance scorecard is a baseline review of the corporate governance practices of the 100 largest listed companies in the Hanoi and Ho Chi Minh City stock exchanges as of Jan. 1, 2009. These companies collectively account for about 90 percent of the aggregate market capitalization of the said bourses. The companies were evaluated on their compliance with Vietnamese laws and regulations and against globally recog- Page 6 © 2011 Institutional Shareholder Services Inc. All rights reserved. The information contained in this report may not be republished, rebroadcast or redistributed without the prior written consent of ISS. 2011 Proxy Season Preview: Southeast Asia nized good corporate governance practices using publicly available materials. covered by existing laws and regulations are not particularly addressed by companies. The principal goal of the baseline review is to develop a standard measure of corporate governance in Vietnam and to identify the more significant areas for improvement in the quality of corporate governance of the country's publicly listed companies. Other Asian countries such as China, Hong Kong, Singapore, Thailand, Philippines, and Indonesia have employed scorecards to improve their respective corporate governance practices. The baseline report offers the following recommendations, among others: Intensive programs on issues such as relatedparty transactions and internal audit, controls and risk management; Extensive training for all participants in the corporate governance field, for instance: The scorecard assessed the participant companies against these five criteria: The rights of shareholders; Equitable treatment of shareholders; Role of stakeholders in corporate governance; Disclosure and transparency; and Responsibilities of the board. These are the subject areas acknowledged by the Organization for Economic Cooperation and Development Corporate Governance Principles as the keys to good corporate governance. In four of the five areas, overall results showed a level of compliance below 50 percent. The area of best compliance, with an overall level of 65.1 percent, is the equitable treatment of shareholders. The lowest, with 29.0 percent, is the stakeholders' role in corporate governance. Other areas with subpar results are shareholders' rights – 46.8 percent, disclosure and transparency – 39.4 percent, and board's responsibilities – 35.3 percent. For directors, on regulatory requirements of Vietnam and on globally recognized best practices; For shareholders, on their rights and the exercise of those rights; For regulators, on supervisory and enforcement practices; and For the media, on raising public awareness of corporate governance issues; Increased disclosure on the board's performance, remuneration, and independence; Auditor election and participation at shareholders' general meetings; Establishment of an audit committee; and Regular scorecard reevaluation and publication of the general result of progress. The results of the baseline review show that corporate governance in Vietnam is still at the incipient stage and that deeper knowledge is absent. The baseline report also notes that corporate governance practice in Vietnamese companies is largely compelled by compliance to regulatory requirements more than a commitment to the practice of sound governance. Thus, issues not Published March 23, 2011 Page 7 © 2011 Institutional Shareholder Services Inc. All rights reserved. The information contained in this report may not be republished, rebroadcast or redistributed without the prior written consent of ISS. 2011 Proxy Season Preview: Southeast Asia This report is provided by Institutional Shareholder Services Inc. ("ISS"), an indirect wholly owned subsidiary of MSCI Inc. ("MSCI"). MSCI is a publicly traded company on the NYSE (Ticker: MSCI). As such, MSCI is not generally aware of whom its stockholders are at any given point in time. ISS has, however, established policies and procedures to restrict the involvement of any of MSCI's non-employee stockholders, their affiliates and board members in the content of ISS' reports. 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