"Division of Corporation Finance 2017 No-Action Letters Issued Under Exchange Act Rule 14a-8", 21 Dec 2017

...The Proposal recommends that the Company establish a human rights committee to review, assess, disclose and make recommendations to enhance the Company’s policy and practice on human rights.

We are unable to concur in your view that the Company may exclude the Proposal under rule 14a-8(i)(7). We are unable to conclude, based on the information presented in your correspondence, including the discussion of the board’s analysis on this matter, that this particular proposal is not sufficiently significant to the Company’s business operations such that exclusion would be appropriate. As your letter states, “the Board and management firmly believe that human rights are an integral component of the Company’s business operations.” Further, the board’s analysis does not explain why this particular proposal would not raise a significant issue for the Company. Accordingly, we do not believe that the Company may omit the Proposal from its proxy materials in reliance on rule 14a-8(i)(7)...