A Better Choice, Clearly

Stewardship Code Implementation Solutions

Glass Lewis has been assisting pension funds and other institutional investors carry out their voting responsibilities since 2003. The UK Stewardship Code, published by the Financial Reporting Council in July 2010, is an effort to promote greater transparency among investor groups with respect to how responsible investment activities are handled. Glass Lewis is uniquely qualified to help investors meet the requirements of the Stewardship Code, as per the following, which lists the Code's Principles and the potential role of Glass Lewis.

The Stewardship Code states that institutional investors should:

Publicly disclose their policy on how they will discharge their stewarship responsibilities.

Glass Lewis helps the majority of our clients in putting together custom voting policies that can be publicly displayed.

Have a robust policy on managing conflicts of interest in relation to stewardship and this policy should be publicly disclosed.

Through use of our vote agent platform, ViewPoint, investors can effectively manage any conflicts of interest. Since Glass Lewis does not provide special consulting or corporate governance advice to public issuers, our clients are assured that potential conflicts are minimized. The Glass Lewis conflict of interest policy can be found at http://www.glasslewis.com/company/disclosure.php

Monitor their investee companies.

Glass Lewis produces proxy research and recommendations on all client holdings. The research team consists of seasoned professionals with advanced degrees in various disciplines and covers all geographies.

Establish clear guidelines on when and how they will escalate their activities as a method of protecting and enhancing shareholder value.

Clients can work with Glass Lewis to determine what the guidelines should be that might trigger such escalation. This determination can be done as part of the policy formulation process or via alerts; the Glass Lewis team of analysts are also available for consultation on subject companies.

Be willing to act collectively with other investors where appropriate.

Glass Lewis hosts periodic "Proxy Talk" conference calls in which shareholder proponents are able to put forth their rationale as to why their proposal or proposals should receive support. This is one way for Glass Lewis clients to act collectively.

Have a clear policy on voting and disclosure of voting activity.

Glass Lewis can create and host a website that will display the voting activity for specified accounts. The site is maintained by Glass Lewis but is launched from the investor's web page. In addition, the Glass Lewis vote platform, ViewPoint, offers a wide range of reporting options that can be customized according to the client's particular needs.

Report periodically on their stewardship and voting activities.

Glass Lewis can support the reporting on voting activities via the ViewPoint platform.