When is a company required to provide the annual report and proxy disclosures mandated by Section 303A ?
Section 303A requires disclosure as to certain matters in a companys proxy statement, annual report to shareholders, SEC filings and the companys corporate web site. Such disclosures encompass independence determinations and matters relating to governance documents, such as committee charters, Corporate Governance Guidelines, the Code of Business Conduct and Ethics and the CEO Certification to the NYSE. The NYSE mandated disclosures are not required in any documents that predate the applicable 2004 Section 303A compliance date. However, companies are welcome to and encouraged to make those disclosures voluntarily whenever it is feasible to do so. Once the 2004 shareholders meeting is held, or by October 31, 2004, whichever is sooner, companies must be in full compliance with Section 303A and have appropriately updated web sites that contain the committee charters, the Code of Business Conduct and Ethics and the Corporate Governance Guidelines. 2) What CEO/CFO certifications filed with
