Date: March 21, 2013

Issue: Corporate Governance

To: U.S. Securities and Exchange Commission

Filing Type: Regulatory

Description: As part of our longstanding efforts to bring greater transparency and accountability to the corporate governance system, the CCMC has developed Best Practices and Core Principles for the Development, Dispensation and Receipt of Proxy Advice, which we hereby place in the public comment file. At their core, these principles seek to address the lack of transparency and accountability of proxy advisory firms, which have failed to keep pace with positive advancements that have been made by other stakeholders in the corporate governance system.

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