The Best Practice Principles for Shareholder Voting Research Group (“BPP Group”), whose members include Glass Lewis, ISS, Ivox, Manifest, PIRC and Proxinvest, have issued a position paper regarding Article 3i, Transparency of proxy advisors, of the recently released proposed revisions to the Shareholder Rights Directive 2007/36/EC. In its paper, the BPP Group raises a number of concerns regarding the hard regulatory approach suggested by the Directive proposals and calls upon the European Commission, Parliament and national governments to support the proportionate, principles-based approach to service supplier oversight overwhelmingly supported by shareholders that is embodied in the Best Practice Principles for Shareholder Voting Research & Analysis, stating that “unwarranted or disproportionate legislation may inhibit the provision of independent information and services that assist investors in the exercise of the very rights and responsibilities that the Directive aims to foster and support.”