Comcast: Request for Report on Providing Oversight and Public Reporting
WHEREAS: Comcast, a company where community and family values are integral to the company’s promotion of its various brands, is also a leading distributor of films that are viewed by young people.
The 2012 US Surgeon General report, Preventing Tobacco Use among Youth and Young Adults concluded that “there is a causal relationship between depictions of smoking in the movies and the initiation of smoking among young people.”
In support of Surgeon General’s report, thirty-eight state Attorneys General wrote to the major studios urging elimination of tobacco depictions in youth-rated movies, stating: “Each time the industry releases another movie that depicts smoking, it does so with the full knowledge of the harm it will bring children who watch it.”
Based on a subsequent 2014 Surgeon General’s report, the Centers for Disease Control and Prevention (CDC) concluded in 2014: “Giving an R rating to future movies with smoking would be expected to reduce the number of teen smokers by nearly one in five (18%) and prevent one million [1,000,000] deaths from smoking among children alive today.”
The need for appropriate corporate governance to address Comcast’s reputational risks arising from this public concern is reinforced by statements of The American Medical Association, American Heart Association, American Lung Association, American Academy of Pediatrics, and the World Health Organization, who have all publicly supported the above Surgeon General’s statements.
Comcast’s Universal Studios is mentioned in the Surgeon General’s 2012 report and in media covering the release of the report. In recent years, the issues raised by the Surgeon General’s report have been covered by a number of national publications including The New York Times, The Los Angeles Times, The Boston Globe and USA Today.
Community and family values are integral to Comcast’s brands. The above publications and statements have attracted significant publicity and linked Comcast to concerns regarding young people’s health. Shareholders are concerned about the management of these risks and consider that Board level oversight is warranted to address these concerns.
As a governance issue, consistent, appropriate, and transparent Board oversight is required to balance company actions that impact young people’s well-being against the company’s reputation and brand value. This responsibility appears appropriate for the Governance and Directors Nominating Committee.
RESOLVED: Stockholders request that the Board amend the Governance and Directors Nominating Committee Charter (or add an equivalent provision to another Board Committee Charter) to include:
Providing oversight and public reporting concerning the formulation and implementation of policies and standards to determine transparent criteria on which company products continue to be distributed that:
1) especially endanger young people’s well-being;
2) have the substantial potential to impair the reputation of the Company; and/or
3) would reasonably be considered by many offensive to the family and community values integral to the Company's promotion of its brands.