Driving the Conversation: Long-Term
Roadmaps for Long-Term Success
Posted by Ariel Fromer Babcock, Allen He,
and Victoria Tellez, FCLTGlobal, on Wednesday, March 6, 2019
Despite clear evidence that investors
prefer long-term communications focused on a few key drivers of
performance, companies remain mired in information demands from all
sides. Long-term roadmaps are a form of investor communication that
brings together a unified articulation of how a company will create
long-term value with the most relevant metrics to track long-term
performance. They have a proven record at leading companies, and
evidence suggests that the majority of investors (especially long-term
investors) prefer this approach. By focusing on key elements of
performance such as competitive advantages, long-term objectives, and
a strategic plan matched with clear capital allocation priorities,
companies can build buy-in among long-term investors who support a
focus on long-term value creation.
Why Long-term Roadmaps?
Survey after survey indicates that investors prefer forward-looking, long-term
guidance around a company’s strategy and expected performance.
post, which represents the collective effort and experience of FCLTGlobal’s
Members, academic experts, and other investment leaders, suggests a way to shift
the investor relations conversation from quarterly “hits” and “misses” toward
how companies create long-term value.
Today’s companies face increasing pressure to respond to information requests
from all sides. It is no surprise that managers and investors are frustrated.
Transitioning away from the quarterly treadmill toward conversations centered on
the long term can simplify investor communications, while simultaneously
strengthening companies’ longer-term shareholder bases, alleviating short-term
pressure and improving the accuracy of valuations. Long-term roadmaps are the
key to this transition.
Long-term roadmaps present a unified view of how a company will create long-term
value with the most relevant metrics to track long-term performance. This format
provides investors with a distillation of a company’s core drivers of growth and
competitive advantages, a company’s long-term objectives and the strategic plan
for achieving them over three to five years, and a company’s priorities for
capital allocation and investment. A long-term roadmap also off investors a
current snapshot and forward-looking trajectory of the company’s performance on
the operational and financial metrics most closely tied to growth. It focuses on
the information that investment decision makers actually need.
additional factors distinguish long-term roadmaps from traditional investor
communications. First, a roadmap’s forward-looking estimates all focus on
objectives one year out, at a minimum. The point is to help investors keep the
company accountable to its plan for long-term value creation, not to provide
fodder for short-term traders and the media. Second, these roadmaps are intended
to foster dialogue between companies and long-term shareholders, rather than
serving as press releases for transient traders. Long-term roadmaps provide the
right kind of shareholders the information they need to engage with and support
corporate managers, thus facilitating the types of long-term investments that
enable ongoing growth.
voices of leading investors and business leaders are clear and underscore the
strong demand for a reorientation toward the long term. For example, 93 percent
of global buy-side investors want guidance from companies on metrics longer than
research shows that public companies can take simple, initial steps to begin the
transition to investor communications oriented toward the long term. As
companies gain experience and comfort with this approach, these early steps can
be easily expanded into a full long-term plan. Many of the world’s leading
companies already employ these approaches today, and their experience off an
example and path for others to follow.
transition to long-term roadmaps has already begun. Long-term investors can
hasten it by calling on companies in which they invest to provide long-term
roadmaps and by setting an example for how shareholders engage. With the backing
of major institutional investors, companies will be able to move forward and
pursue long-term roadmaps today.
Short-term guidance is not important for our evaluation for new or existing
investments because it does not relate to our long-term investment horizon.
Rather, we evaluate companies positively when they refrain from this short-term
practice, particularly when they share a long-term roadmap instead.
– Chuon-Yi Ong, Senior Vice President, Public Equities, GIC Private Limited
What Do Investors Want?
Corporate managers have good reason to feel frustrated by ever-increasing
demands for additional information. As Mozaff Khan, George Serafeim, and Aaron
Yoon have shown, firms that perform well on immaterial metrics do not
significantly outperform firms with poor ratings on the same issues. Disclosure
of these immaterial metrics adds little to no value for investment decision
According to a study from McKinsey & Company, long-term investors own more than
70 percent of the shares of US companies. For these investors, short-term
guidance does little to inform their investment choices; they simply distract
companies and their investors from the metrics that truly matter.
UN-supported Principles for Responsible Investment, whose signatories represent
more than $80 trillion in investable assets, urge companies to “focus on
communicating issues and metrics that are relevant to the long-term success of
the business.” In addition, a survey of investment decision makers conducted by
FCLTGlobal indicated that 86 percent of respondents would like companies to use
a minimum three-year time horizon for forward-looking targets.
Notable business leaders voice the same sentiment. “Clear communication of a
company’s strategic goals—along with metrics that can be evaluated over
time—will always be critical to shareholders,” wrote Warren Buffett, chair and
CEO of Berkshire Hathaway, and Jamie Dimon, chair and CEO of JPMorgan Chase, in
an editorial for the Wall Street Journal. BlackRock chair and CEO Larry
Fink echoes this point. In his 2018 annual letter, he wrote, “I want to
reiterate our request, outlined in past letters, that you publicly articulate
your company’s strategic framework for long-term value creation.” Harvard
professor and former US Treasury Secretary Larry Summers agrees, “Wise corporate
leaders should give a sense of their long-term vision on at least an annual
basis. Investors who insist on such information are only being reasonable.”
Investor relations organizations also acknowledge that long-term plans with
long-term metrics are an essential investor relations tool. In fact, the US
National Investor Relations Institute (NIRI) recently amended its policies to
respond to this investor preference. As its policies now state, “NIRI believes
that an undue focus on short-term, single-point guidance is undesirable and that
all relevant audiences—primarily investors, financial analysts, and the news
media—are better served when public companies focus their guidance on their
long-term strategy and business value drivers.”
Roadside Attractions: The Benefits of a Long-term Plan
Implementing a long-term approach to investor communications offers tangible
benefits, both financial and otherwise, for participants on both sides of the
Chiefly, a long-term approach attracts long-term investors. As professors
François Brochet, Maria Loumioti, and George Serafeim demonstrate, focusing on
short-term metrics attracts transient shareholders. By contrast, companies that
focus on long-term topics in their investor communications attract and build a
long-term investor base. Building that long-term investor base is important, as
it reduces a company’s cost of equity, encourages greater fixed investment, and
is ultimately associated with higher returns.
plans can also help management respond in the face of short-term pressure (e.g.,
from activists). Investors that understand and believe in management’s strategy
and plan for execution are more likely to support the company through ups and
downs, serving as a buff or even potential deterrent to activist attack. As
FCLTGlobal’s research on quarterly guidance demonstrates, longer-term guidance
(in this case, annual) does a better job muting share price volatility than
short-term guidance, alleviating one source of potential short-term pressure.
the analyst level, a long-term roadmap can ensure a more accurate valuation.
According to McKinsey & Company, 70 to 90 percent of company value is related to
cash flows three or more years out. Investor communications that don’t speak to
that horizon leave markets to fill in the blanks, often incorrectly. For
example, the 2° Investing Initiative (2°ii) found that even though financial
analysts and data providers produce forecasts for five to 10 years, companies
typically only provide forecasts for the next quarter to one year. This
disclosure gap increases the uncertainty of stock valuations by analysts, making
it more likely that the market could get a company’s future earnings
potential—and stock market valuation—very wrong.
benefits aren’t all financial. In addition to freeing investor relations
departments from addressing the short-term “noise” that doesn’t help their
investors, research published by Timothy Youmans and Brian Tomlinson in MIT
Sloan Management Review suggests companies that use long-term plans have
also reported better success at attracting and retaining personnel.
Similarly, managers from 66 organizations in the International Integrated
Reporting Council reported that developing and communicating a long-term
strategy delivered meaningful benefits internally: 79 percent of managers
reported that business decision making had improved, and 78 percent experienced
better collaboration between the board and management.
Speed Bumps: Overcoming the Points of Resistance
Although seemingly a simple and powerful tool, long-term roadmaps can face
resistance for both internal and external reasons. Fortunately, some of the
world’s leading companies have proven that such resistance can be overcome. When
it is, change can happen quickly, especially when investors themselves join the
effort to promote long-term planning and communications.
Interviews with FCLTGlobal’s Members and others offer a perspective on how to
address common sources of resistance. For example, many management teams are
concerned about revealing their “secret sauce” by sharing too much information
on their future plans. British pharmaceutical company GlaxoSmithKline’s (GSK’s)
vice president of investor relations, Mel Foster-Hawes, acknowledged this
tension in her approach: “When sharing long-term information, companies need to
balance the benefits of disclosure with the risks of sharing competitive
insight. At GSK, we manage that tension by signaling key inflection points in
the business and sharing detail around those to build credibility for the
Others are worried about having their feet held to the fire if reality doesn’t
line up with the forecasted plan, particularly for reasons that are outside the
company’s control. While some of this is inevitable—and responding to events is
a reality—a well-communicated long-term roadmap typically includes a frank
discussion of the company’s assumptions and any risks that might upend them.
Investors informed by a long-term plan are prepared for a shift in guidance,
strategy, and performance when real-world conditions require a change from
initial plans. Indeed, this is an area where professional investors excel,
incorporating new information into their investment thesis and rapidly adjusting
to market change. In this way, long-term investors follow the example often
attributed to famed economist John Maynard Keynes: “When my information changes,
I change my mind. What do you do, sir?”
American multi-national chemical company Dow Chemical’s Vice President of
Investor Relations, Neal Sheorey, finds that his investors routinely assess how
future real-world conditions could impact his company’s performance. He tackles
the problem of forecasting conditions by providing a vision of what could be
possible based on historical market swings. In other words, rather than trying
to guess the future, he establishes scenarios based on past outcomes. This
provides a framework for investors to understand the inherent risks in the
company’s long-term strategy and to understand how performance will naturally
adjust if and when real-world conditions shift.
points of resistance can even be turned into opportunities. Managers may be
concerned that discussing their company’s risks in a direct way may scare away
investors. But experience shows that long-term companies can use frank, balanced
conversations about risk as an opportunity to enhance investors’ understanding
of what goes into achieving the company’s strategic vision. They accomplish this
by discussing downsides and areas of potential upside. For example, Dave Huizing,
vice president of investor relations at Dutch health, nutrition, and materials
company DSM, uses his conversations about climate risk to highlight the
company’s sustainability mind-set. He emphasizes how DSM’s investments in
sustainability offer the company an attractive set of longer-term growth
opportunities while lowering their overall risk.
Long-term investors also have an important role to play. Too often, demands from
short-term investors or undue focus on short-term performance take center stage.
Why, companies ask, should they bother developing or disseminating long-term
plans or roadmaps when short-termism is so pervasive? The answer is that
investor surveys overwhelmingly indicate that money managers want long-term
information. Emerging evidence indicates that markets more broadly do react to
long-term plans. CECP, in conjunction with the research firm KKS Advisors,
analyzed the content of long-term plans shared by corporate managers at CECP’s
CEO Investor Forums, as well as the stock market reaction following these
presentations. Their research suggests that investors do trade on long-term
information: “The results show abnormal reactions for both stock prices and
trading volume for three and five days after the [long-term plan] presentation.
… The stock price and share turnover findings imply that the long-term plans
presented at the CEO Investor Forum contain information that investors find
relevant and meaningful [to their investment decisions].”
reorienting investor communications can sometimes seem like turning a
supertanker, change, once initiated, can happen quickly. Take the issuance of
guidance—forward-looking, numerical forecasts of a company’s anticipated
performance. Short-term quarterly earnings guidance peaked in popularity in
2003, when 75 percent of US firms issued quarterly forecasts. As the harm caused
by short-term guidance became better understood (described in our earlier work
Moving Beyond Quarterly Guidance: A Relic of the
Past), there was a significant reversal in trend—just 27.8
percent of S&P 500 companies gave quarterly earnings guidance in 2017.
same shift can happen for long-term guidance. On a global basis, long-term
forecasts have a small following: 8.7 percent of MSCI All Country World Index (ACWI)
constituents issued longer-term guidance in 2017 (guidance for periods greater
than one year into the future), far fewer than the 44 percent of constituents
that issued annual guidance. If long-term investors spoke as loudly as their
shorter-term counterparts, these numbers could rapidly rise.
Rules of the Road: What Makes a Good Long-term Roadmap
Long-term roadmaps are about cutting through the short-term frenzy and focusing
on what matters. Companies that successfully implement long-term
communications—whether roadmaps alone or a full suite of long-term investor
communications approaches—focus on the information that really drives decision
making for long-term investors. In 2015, the Focusing Capital on the Long Term
initiative introduced a suggested framework for long-term investor
communications. The report,
Straight Talk for the Long Term,
highlighted 10 elements that institutional investors, corporate strategy
experts, and CEOs recommend companies include when formulating their long-term
communications plans. These 10 elements constitute a complete plan for long-term
investor communications. Collectively, they represent what investors view as the
Companies are typically comfortable with the first few elements. Expressing
their purpose, mission, and vision; explaining their business model and core
drivers of growth; and sharing management’s market view are all familiar talking
points for management teams in informal conversations. But taking the leap to
sharing a complete long-term plan in a formal way seems more challenging.
Discussing strategic goals, laying out a detailed execution plan, providing
metrics and targets that track strategic progress, and tying that progress to
capital allocation priorities and likely risks require careful consideration and
a coordinated approach.
from zero to 10 is understandably daunting, but a long-term roadmap offers an
achievable first step. To help companies determine how best to start, FCLTGlobal
surveyed investment decision makers to identify their priorities for long-term
Although the overwhelming preference remains for a complete long-term plan,
respondents were in broad agreement that a good long-term roadmap lays out a
clear vision for the future based on the company’s competitive advantages and
core drivers of growth—the underlying determinants of a company’s success; it
then links these to long-term objectives and capital allocation priorities.
These elements, combined with a strategic plan to achieve those objectives and a
set of key performance indicators (and long-term guidance for them), constitute
the backbone of a good roadmap.
leading global companies, including British energy firm BP, GSK, Japanese motor
manufacturer Nidec, North American home improvement retailer The Home Depot,
DSM, and British-Dutch transnational consumer goods company Unilever, have
adopted long-term roadmaps (or, in some cases, complete long-term plans) to aid
in their investor communications.
examples demonstrate that the shift to long-term communications is achievable
and desirable, even for the largest, most scrutinized companies in markets
across the globe.
Companies that have implemented this approach find aligning investor
communications with long-term objectives allows them to speak to the horizon
that a majority of their investors find most relevant. But how can companies
best achieve that combination of information? As a start, they can think about
where the business is likely to be several years down the road. A good roadmap
explains how a company will get there and establishes specific, interim goals
that track the achievement of this vision. From there, they can elaborate on the
key elements identified as most important by long-term investors. These elements
include the following:
Competitive Advantages and Core Drivers of Growth:
can be identified by considering the questions: “At what do we excel?” or “What
differentiates us?” In the same vein, companies need to identify the sources of
current and future growth: “What will drive revenues in the future?” and “What
trends are we positioning the company to take advantage of?”
companies include details on the competitive landscape, key customer segments,
primary technologies and products, and internal factors such as intangible
assets and organizational structure. Most investors suggest a focus on the input
factors (what drives the company and its strategy) and less attention on output
factors (what the earnings are now, next month, and next quarter).
clearly defines management’s view of the four major core drivers of growth for
the motor manufacturing company: automotive electrification driven by a push for
decarbonization of the transportation sector; the expansion of robot
applications, particularly in the food, logistics, and service industries;
continued demand for power-saving motors for home appliances; and the rising
demand for further automation in the agriculture and logistics sectors, driven
by increasing labor constraints. These core drivers of growth are clearly linked
to the company’s five-year plan, and management offers an annual review and
update on how they see each developing.
A good roadmap provides a clear picture of where the company is going in the
next three to five years and beyond, including specific targets at both the
enterprise and business unit level. These objectives tend to include a mix of
operational and financial goals, as well as related assumptions.
companies present a vision for the future and discuss how they are positioning
the strategy to achieve that, this is the most believable sort of guidance. In
our view, a two- to three-year outlook tied to a longer-term vision is the gold
standard for investor communications.
– Felix Lanters, Head of Equities, PGGM
example, to ensure simplicity and clarity, DSM focuses on two high-level,
long-term financial objectives: sharing target ranges for EBITDA (earnings
before interest, taxes, depreciation and amortization) and average, annually
adjusted net operating free cash flow. DSM’s investor relations team
communicates its value proposition, while also building credibility for the
strategy, by sharing a detailed annual Factbook that includes a review of past
performance against guidance metrics, segment milestones toward achieving group
targets, the details of key projects contributing to core growth initiatives,
and the company’s long-term objectives.
our interviews with institutional investors, we found broad agreement that a
good roadmap also articulates the company’s high-level strategic plan and the
set of actions management plans to take to achieve their long-term objectives.
The strategic plan can also be used to frame discussions of critical risk
factors, both upside and downside, that could impact strategy, especially those
related to core business drivers. Using scenario analyses where appropriate can
also be helpful to illustrate risks and assumptions and explain forecast ranges.
Motors clearly lays out its business model and strategic priorities in its
roadmap, identifying long-term opportunities and listing key risks. The company
presents its strategic framework, detailing objectives by segment, as well as
segment-level key initiatives and actions taken, and spotlighting future areas
of focus for each segment. By highlighting risks alongside the business model,
the company elevates the risk conversation from one buried in legalese to one
related to business strategy, potential impacts, and mitigation tactics.
Capital Allocation Priorities:
Discussions of a company’s strategic plan go hand-in-hand with how the company
allocates capital (both its sources and its uses of cash). Laying out specific
capital allocation priorities lends credibility to the strategy and helps
illustrate how the company expects to finance its path forward. As GSK’s CEO
Emma Walmsley emphasizes, “Until you put the money where you say your strategy
is, it’s not your strategy.”
companies have recognized the value of communicating their capital allocation
priorities to investors. In 2017, 21.8 percent of MSCI ACWI constituents offered
annual or longer capital expenditure (capex) guidance. Perhaps unsurprisingly,
companies in capital-intensive industries, or industries where investing in
long-lived assets or projects is common, tend to use capex guidance most
frequently. In 2017, 59.4 percent of ACWI energy sector companies, 38.8 percent
of materials companies, and 36.2 percent of utilities companies provided annual
or longer capex guidance.
Home Depot shares its planned approach to capital allocation with investors and
explains how this allocation supports its long-term objectives. Alongside its
strategic framework, the company issues three-year targets, updated annually and
rolled forward at periodic, company-hosted investor conferences (for example,
2018 targets were first introduced at its 2015 Investor Conference, while 2020
targets were first issued at the 2017 Investor Conference).
Home Depot’s capital allocation detail includes total forecasted spend, a
breakdown by spending category, and an outline of the return on invested capital
guidelines the company uses to inform its investment decisions—including its
target mix of debt to equity, targeted debt/EBITDAR (earnings before interest,
taxes, depreciation, amortization and restructuring) ratio, and benchmarking
criteria. Return of capital to shareholders is also included in the capital
allocation plan, highlighting the target payout ratio and preference for use of
cash to buy back shares only after meeting the needs of the business (and only
if the buybacks are deemed “value creating”).
Key Performance Indicators (KPIs):
Successful long-term roadmaps provide a mix of financial and operational metrics
(KPIs) tied to the company’s core drivers of growth. These metrics allow
investors to track progress toward long-term objectives and engage the executive
team in dialogue over their progress.
Metrics that help investors understand and follow the company’s progress over
time are the most helpful. These are typically metrics (1) that the company can
comfortably predict, (2) over which the company has a reasonable degree of
control, and (3) that are difficult for outsiders to estimate despite their
importance to the company’s strategy. Companies often contextualize these
metrics by connecting them to their long-term goals and by offering a three- to
five-year outlook for each (as a range, not a point estimate), as well as to key
risk factors and opportunities influencing that outlook. Further detail often
includes tying metrics to management incentives and capital allocation plans,
which can further help companies build credibility for their strategy among
organization focused on developing long-horizon projects and assets, BP takes a
similarly long-view with investor communications. The company offers a five-year
plan for company performance, together with interim annual targets, and
regularly reports against 15 financial and operational KPIs. These KPIs are
shared with a five-year history for reference and include clear definitions for
how each metric is calculated, a brief discussion of the recent trend and any
relevant considerations, and information on how metrics are tied to compensation
focuses its metrics and targets on things the company and its employees can
influence. Examples include their “Reserves Replacement Ratio,” which measures
the extent to which that year’s production has been replaced by new proven
reserves added to the reserve base, and their “Underlying Replacement Cost
Profit,” which measures the replacement cost of inventories sold in the period.
By using a mix of operational and financial targets, BP makes it easy to track
progress toward long-term objectives while stripping out the “noise” caused by
factors outside the company’s control.
Identifying Appropriate Metrics
metrics belong in a company’s roadmap? Investor relations professionals have
found it’s important to monitor those that both management and investors
consider most important to valuing and evaluating a company. Here are some
Get a sense of
commonly used industry metrics by surveying peers and competitors.
investors which metrics they find most helpful.
relevance of a company’s internal metrics for external stakeholders. If it’s
important enough to be used as a yardstick for business success, then odds are
it should be on the short list of metrics to be publicly shared, particularly
if it’s tied to incentive compensation.
A number of
organizations, including the Sustainability Accounting Standards Board, and
the International Integrated Reporting Council offer various frameworks and
metrics for disclosure which can link to long-term roadmaps.
Research by Alex Edmans, Mirko Heinle, and Chong Huang offers cautionary
evidence to keep in mind when selecting metrics. The authors demonstrate that as
long as stock markets better incorporate “hard” information than “soft,”
disclosing more hard information will skew managers’ real decisions toward
improving hard performance measures (such as improving earnings) at the expense
of soft performance measures (such as intangible investments).
the study focuses on the impact of an increase in reporting frequency, this
finding is instructive for forming long-term roadmaps as well. Long-term targets
could lead to excessive management of those targets, so that companies sharing
KPIs could consider including a balanced mix of both financial (“hard”) and
operational (“soft”) metrics as targets. This mix makes it less likely that
managers will game one metric over another and will ensure their focus remains
on achieving both.
Hitting the Road: Developing and Putting a Long-term Roadmap into Practice
Effectively delivering a long-term roadmap to the market requires companies to
lay critical groundwork, both internally and externally. Investor relations
professionals interviewed for this project emphasized that roadmaps require
internal buy-in and willpower to stick to this approach. For example, for the
past 10 years, DSM has prioritized sustainability as its key business driver.
The combination of the shifting business portfolio and DSM’s
sustainability-based growth initiatives required investors to understand the
long-term plan and appreciate the company’s strategic investment goals. To
achieve that understanding, the investor relations and corporate communications
departments worked with the board, CEO, and CFO to develop a unified
communications strategy focused on the long-term storyline, as well as
developing stakeholder buy-in for the long-term strategy. Similarly, GSK’s
launch of its long-term roadmap followed months of work, which included
collecting feedback from numerous stakeholders, both internal and external.
constructing a long-term roadmap, it helps to keep things simple. Unilever CEO
Paul Polman’s concluding remarks at the company’s 2017 Investor Event consisted
of only seven slides. Starting with reviewing the company’s strengths, he then
summarized how Unilever would build on these strengths to drive the next phase
of growth; laid out specific short-, medium-, and long-term priorities;
highlighted potential sources of risk; and closed by reconfirming the company’s
the roadmap has been developed internally, it’s time to take it on the road.
Investors suggest that companies consider launching the plan at a high-profile
event, such as an annual meeting, capital markets, or investor day. In fact, 79
percent of the investors we surveyed identified a company-hosted investor or
capital markets day as the best venue for sharing a long-term plan or roadmap.
Post-launch, management and investor relations professionals start every
conversation, including those with the sell side and the media, by reminding
their audience of the company’s long-term goals. Companies have also found it
valuable to provide investors with exposure to wider senior management, beyond
just the CEO or CFO. Demonstrating depth of leadership, backed up by unified
messaging, makes investors comfortable that the whole team is on board with the
long-term plan and working together to execute it. Finally, companies find being
clear about how and when the roadmap will be updated helps investors anticipate
the communication cadence. On that question, investors were clear: they prefer
annual updates by a significant margin.
Getting to the Destination
Long-term roadmaps offer a potential bulwark against short-term pressures. In
our study, 100 percent of investors said they either always or occasionally
encourage companies to share their long-term plans.39 More than 86 percent of
investment decision makers say they want metrics oriented toward expected
performance at least three years out. Success stories show that the hurdles to
adopting long-term investor communications can be overcome.
long-term roadmap is a manageable first step toward building a complete
long-term communications strategy. By sharing core drivers of growth,
competitive advantages, long-term objectives, and the company’s strategic plan
(including capital allocation priorities and interim targets), companies can
provide investors with the information they need without getting caught in the
frenzy of quarterly targets. Investment decision makers have made it clear what
they want: a long-term roadmap to provide a unifying framework and vehicle to
transitioning to long-term roadmaps, companies can begin to build the
communications foundation for what really matters: creating long-term,
complete publication, including footnotes and appendix, is available
Harvard Law School Forum
on Corporate Governance and Financial Regulation
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