UK: GC100 publishes response to the FRC Combined Code review

GC100 - the Association for the General Counsel and Company Secretaries of FTSE100 companies - has published its submission to the Financial Reporting Council with regard to the proposed changes to the Combined Code on Corporate Governance: see here (pdf).

The GC100 continues to argue that substantial change is not required and that greater prescription should be avoided. It also notes, amongst other things, its disappointment that the FRC has retained the description "comply or explain" to describe the basis of the Code's operation in preference to "apply or explain". The GC100 membership continues to be divided on whether annual re-election for all directors is preferable to three year rotation.