Overview

• On September 15, 2025, the SEC’s Division of Corporation Finance issued no-action relief allowing ExxonMobil to implement a voluntary program letting retail investors provide standing instructions to vote with board recommendations.
• Participants enroll at no cost, receive annual off-season reminders, retain the right to opt out at any time, and can override standing instructions by casting their own votes for any meeting.
• The program covers annual and special meetings and excludes actions by written consent, with an option for shareholders to exclude contested director elections or certain M&A proposals from their standing instruction.
• Votes under standing instructions will be processed by the company’s vote‑processing agent after the definitive proxy is filed, with sensitive shareholder information kept by the agent and not shared with the issuer.
• The SEC Staff indicated companies closely following Exxon’s approach may rely on the relief after consulting with Staff, though issuers still face state-law questions, operational buildout, and uncertain costs and uptake.