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ARTICLE · 16 OCTOBER 2025

SEC Allows Exxon Mobil To Implement A Retail Voting Program To Support The Board's Recommendations – Is Such A Program Coming To Canada?

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On September 15, 2025, the Securities and Exchange Commission (the "SEC") issued a no-action letter confirming that it would not recommend enforcement action against Exxon Mobil Corporation...

CanadaCorporate/Commercial Law
Paul Davis
Paul Davis
Sadaf Karimi
Sadaf Karimi
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Introduction

On September 15, 2025, the Securities and Exchange Commission (the "SEC") issued a no-action letter confirming that it would not recommend enforcement action against Exxon Mobil Corporation ("Exxon") with respect to the implementation of their retail voting program (the "Voting Program"). The Voting Program is a voluntary, no-cost program whereby retail investors could authorize a standing voting instruction requiring Exxon to vote their shares based on the recommendations of Exxon's board of directors (the "Board") at each duly called annual general or special shareholder meeting. One of the stated objectives behind the Voting Program is to address and combat low shareholder participation turnout.

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The foregoing provides only an overview and does not constitute legal advice. Readers are cautioned against making any decisions based on this material alone. Rather, specific legal advice should be obtained.

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