Report Feedback Statement 

The Report Feedback Statement (RFS) service provides a unique opportunity for public companies and shareholder proposal proponents – the subjects of Glass Lewis research – to submit feedback about the analysis of their proposals, and have comments delivered directly to Glass Lewis’ investor clients. Corporate issuers and shareholder proposal proponents alike are eligible to participate in this service and will provide their statements directly to Glass Lewis’ research and engagement team, which will in turn distribute them to clients within the Glass Lewis research and voting platforms.

This service is operating as a pilot in the 2019 proxy season (March through May 2019). Please see the below FAQs for more details.

Sign Up for the Report Feedback Statement

Frequently Asked Questions

The Report Feedback Statement service provides a unique opportunity for public companies and shareholder proposal proponents – the subjects of Glass Lewis research – to submit feedback about the analysis of their proposals, and have comments delivered directly to Glass Lewis’ investor clients. Corporate issuers and shareholder proposal proponents alike are eligible to participate in this service and will provide their statements directly to Glass Lewis’ research and engagement team, which will in turn distribute them to clients within the Glass Lewis research and voting platforms.

Please note that this service is not currently available for special meetings, including mergers and acquisitions and contested meetings.

For the 2019 proxy season, on a first-come-first-served basis, Glass Lewis will pilot the Report Feedback Statement service to a limited number of public companies and shareholder proposal proponents. Subscribers to the service will have the opportunity to express their differences of opinion with Glass Lewis’ analysis through a unique, focused channel to 3,000+ individuals who subscribe to Glass Lewis’ research and voting services.

Please review the RFS Etiquette Guide for guidance on acceptable content for a Report Feedback Statement.

The creator of a Report Feedback Statement must:

• Be a U.S. issuer or shareholder proposal proponent at a U.S. company annual general meeting. (All)
• Participate in Glass Lewis’ free Issuer Data Report program and complete the Issuer Data Report process prior to issuing their Report Feedback Statement. (Issuers Only)
• Purchase the relevant annual general meeting report directly from Glass Lewis. Participants that only use third parties (e.g. solicitors, law firms and other advisors) to get information about Glass Lewis’ analysis are not eligible to subscribe to the Report Feedback Statement service. (All)
• Clearly identify the names of shareholder proponents in the company proxy for any shareholder proposals up for vote at the relevant meeting. (Issuers Only)
• Sign the Report Feedback Statement Terms and Conditions. (All)

Yes. The number of pilot participants will be capped at a maximum of 12 companies and/or shareholder proponents per week during the main U.S. season (March through May). The weekly maximum is subject to change depending on the length and complexity of the feedback statements received for any week.

Yes, this service is limited to feedback on annual general meetings only. Until further notice, it is not available for special meetings, including proxy contests and mergers and acquisitions.

Further, companies that are putting shareholder proposals to a vote at annual general meetings and do not identify the names of the shareholder proponents in their proxy statements are not qualified to subscribe to the service.

Issuers
To subscribe to the Report Feedback Statement service, issuers must purchase a copy of the relevant Proxy Paper® meeting report directly from Glass Lewis (on a one-time basis or via subscription) and pay a distribution fee for each Feedback Statement submitted. An additional distribution fee applies if an issuer opts to distribute a second Report Feedback Statement.

Shareholder Proposal Proponents
The fees associated with participation in the Report Feedback Service include the cost of acquiring a copy of the relevant Proxy Paper report (on a one-time basis or via subscription) and a distribution fee for each Feedback Statement submitted. An additional distribution fee applies if a shareholder proposal proponent opts to distribute a second Report Feedback Statement.

For more specifics on pricing, please submit a request by selecting the “SIGN UP FOR REPORT FEEDBACK STATEMENT” button at the top of the page.

To give investors reasonable time to consider Report Feedback Statements submitted by companies prior to voting, companies will need to address any factual errors discovered upon publication of a Glass Lewis Proxy Paper report within two (2) business days of publication of such research report.

Glass Lewis will complete the normal process for addressing factual errors discovered upon publication of analysis and will notify clients of the corrections via Glass Lewis’ republishing process. Glass Lewis does not charge fees for bringing factual errors to our attention.

If, upon addressing any factual errors discovered upon publication of the report, the issuer or shareholder proponent would like to issue a Report Feedback Statement highlighting differences of opinion, they can do so, as long as the statement is delivered no later than four (4) business days from the initial publication of the report.

No. Companies that neither subscribe to the Issuer Data Report service nor purchase the Proxy Paper report directly from Glass Lewis but have identified a purported factual error in the Proxy Paper report following publication of the report can still notify Glass Lewis of the purported factual error or omission.

The same applies if a shareholder proposal proponent believes there is a factual error in the Proxy Paper report that covers its proposal.

Report Feedback Statements should be submitted on the letterhead of the submitting organization (issuer or shareholder proponent) in PDF format.

Each statement must be signed by an executive at the organization, authorized to issue external statements on behalf of such organization, and feature contact information to enable investors to follow up with the organization. If the person submitting the letter is different than the person who signed the letter or who is listed as the contact person regarding the letter, the person submitting the letter must provide his/her detailed contact information, including name, title, email and phone number(s). Glass Lewis can only accept letters that meet these guidelines and comply with the RFS Etiquette Guide.

For all subscribers, the deadline for Report Feedback Statement submissions is four (4) business days following Glass Lewis’ publication of the relevant Proxy Paper report, so long as the subscriber has met all the other prerequisites required to submit a Report Feedback Statement.

Other circumstances may impose additional time requirements. For example, companies that want to subscribe to the Report Feedback Statement service must enroll in the free Issuer Data Report program. Enrollment for the Issuer Data Report program is not limited and available on a rolling basis. However, enrollment is not guaranteed if requested within 30 days of the annual general meeting.

Glass Lewis will not edit or modify the content of Report Feedback Statements and will only distribute mutually approved Report Feedback Statements without any alterations, except for the addition, by Glass Lewis, of a standard content disclaimer.

Prior to publishing a Report Feedback Statement, Glass Lewis may request that a company or shareholder proponent revise its Report Feedback Statement if it: 1) clearly violates the RFS Etiquette Guide established for the service, 2) highlights factual errors that Glass Lewis addresses at no cost or obligation to the company, 3) is inconsistent with or irrelevant to the purpose of the Report Feedback Statement service, or 4) may cause Glass Lewis to be deemed to be engaging in a solicitation under applicable laws or regulations.

Investor clients who have already downloaded the Glass Lewis Proxy Paper that is the subject of a Report Feedback Statement will receive an email with the Report Feedback Statement and the Glass Lewis response to the Report Feedback Statement. Further, a disclosure note, notifying all investor clients that a Report Feedback Statement and a Glass Lewis response to the statement are available for download within the Viewpoint and GlassLewis.net applications, will be added on the first page of the Proxy Paper report.

Please note that Glass Lewis is not authorized to distribute a Report Feedback Statement to organizations that are not Glass Lewis clients, including the media. Glass Lewis will direct requests from non-clients for a Report Feedback Statement to the statement’s creator.

Issuers and shareholder proponents are permitted to submit one Report Feedback Statement per annual general shareholder meeting. However, if the company makes an additional public filing that results in a material revision of the Glass Lewis report, at Glass Lewis’s discretion, issuers will be permitted to submit one additional Report Feedback Statement at full cost within two (2) business days following the publication of the revised Glass Lewis research.

No. The entirety of the Report Feedback Statement process occurs after the publication of Glass Lewis’ Proxy Paper report; as such, this service will not impact lead times. Furthermore, service users are required to submit their qualifying Report Feedback Statements within four (4) business days after publication of the relevant Proxy Paper report to ensure all resulting content can be distributed to investor clients in a timely fashion prior to voting deadlines.

As with other product launches, Glass Lewis has analyzed the requirements and resources required to support this new service. The 2019 proxy season pilot of the Report Feedback Statement service will provide important real-time data and results that will inform our expansion of the service.

The purpose of the Report Feedback Statement service is to allow participants to more fully and directly express their views on any differences of opinion they may have with Glass Lewis’ research. It is not intended to be a forum to evaluate or critique other firms.

If a participant is concerned with the accuracy of any third-party data contained in a Proxy Paper report, these concerns should be addressed directly with the supplier. In instances where Glass Lewis has explicitly indicated its reliance on specific data provided by one of its third-party data suppliers, to form its analysis or vote recommendations, feedback may be provided on the relevance of such data.

As it relates to other proxy advisors, participants should refrain from, directly or indirectly, commenting on the views, analysis and vote recommendations of other proxy advisors, and from providing a comparative analysis between the research published by Glass Lewis and the research published by another proxy advisor.

As a reminder, issuers and shareholder proponents must always follow the RFS Etiquette Guide. Glass Lewis retains the right to refrain from distributing comments on information unrelated to Glass Lewis’ analysis if it believes such commentary falls outside the scope of the purpose of the Report Feedback Statement service.

For the 2019 proxy season pilot, Glass Lewis can provide the number of investors who were sent the Report Feedback Statement via email and the number of investors that downloaded the Proxy Paper report, pre- and post-distribution of such email. Relevant statistics will be available from Glass Lewis within 30 days after the company’s shareholder meeting has occurred.

Privacy is a critical component of Glass Lewis’ obligation to clients. Following the 2019 proxy season pilot, Glass Lewis will determine if there is relevant analytic information that could be provided on an aggregated basis in future iterations of the service. In no event will Glass Lewis disclose any client-specific information.

Upon request, Glass Lewis will provide quarterly reports that list the issuers and shareholder proponents that subscribed to the Report Feedback Statement service.