Stewardship in Action: Engagement Snapshots on Consumer Rights and Unethical Business Practices

This article is part of a Stewardship in Action series that relays brief, on-the-ground snapshots of how Glass Lewis’ Stewardship team engages publicly-listed companies on behalf of investors on a range of material environmental, social, and governance (ESG) issues. Installments one and two can be read here and here. The engagements are dedicated to helping institutional shareholders identify and address ESG issues that can potentially affect the long-term value of their portfolio companies. Engagement on these issues is essential in fostering constructive dialogue and positive change.¹ All company names have been anonymized.

Snapshot One: Protecting Consumer Rights With a Transportation Technology Company

Investor Strategies for Engaging on Consumer Rights

Investors can adopt a range of strategies to engage with companies on consumer rights-related risks. Disclosure is a key focus. Investors can encourage companies to publicly share clear and reliable consumer rights policies that address areas such as product quality and safety, data protection, fair marketing and complaint handling. Investors may also ask companies to be more transparent about how they track consumer issues, how quickly they are able to resolve them, and how effective their response mechanisms are. Enhanced disclosure allows shareholders to better understand how well a company protects consumers and whether its practices align with regulatory expectations and societal norms.

Investors may also seek greater governance transparency, including evidence of board-level oversight of consumer risks. This could involve dedicated committees or regular reporting on customer complaints, safety incidents, and data privacy breaches. In sectors with heightened consumer exposure or where controversies are ongoing, investors can advocate for the integration of consumer-focused performance indicators into executive remuneration frameworks, effectively linking pay to outcomes such as customer satisfaction, resolution rates or compliance performance.

Reporting frameworks such as the GRI, SASB standards for consumer-facing sectors and regional legislation such as the EU’s Digital Services Act or Consumer Protection Cooperation Regulation can serve as benchmarks for effective consumer rights disclosures. These standards also allow investors to compare and identify best practices across industries.

Investors can further assess whether companies are dedicating sufficient resources into consumer protection systems, such as training for frontline staff, data security infrastructure, and redress platforms. Evidence from studies in consumer behavior and corporate responsibility has shown that companies that invest meaningfully in these areas often benefit from increased brand loyalty, reduced litigation risk and better long-term financial performance.

Lastly, investors should be mindful of the growing influence of media and social media, as consumers increasingly use these platforms to voice criticism, expose harmful practices and mobilize public pressure. Negative incidents can quickly escalate into reputational crises when amplified online. For example, Wells Fargo’s years-long misconduct involving unauthorized account openings only gained full public attention after widespread media coverage and viral consumer backlash, leading to billions in fines, regulatory sanctions and lasting damage to its reputation and investor confidence. In this context, companies that fail to address consumer grievances openly risk losing stakeholder trust. Investors can play a key role by encouraging companies to proactively monitor and respond to consumer feedback transparently and effectively.

Where concerns persist, third-party audits or validation procedures can provide independent assurance regarding a company’s consumer rights practices, especially in areas such as product safety or complaint resolution. These audits may be particularly valuable in high-risk sectors or in cases where regulatory violations or consumer controversies have occurred.

The Company: Driver, Inc. offers digital‑enabled services across multiple international markets, including regions in the Americas, in the United States, Canada, Latin America, Europe, the Middle East, Africa, and parts of Asia.

The Issues: We initiated our engagement efforts with Driver, Inc. in 2024 in response to long-standing safety concerns and high-profile incidents involving passengers and drivers.

Since the mid-2010s, the company has faced ongoing issues related to security, privacy, and customer safety. The company has been the subject of numerous complaints and lawsuits involving sexual assault, violence and unsafe conditions for both passengers and drivers. During this period, a regulatory body fined Driver Inc. for withholding data on sexual assault and harassment claims. In response, Driver Inc. released safety reports. The reports disclosed a significant number of sexual assault incidents, highlighting a persistent systemic problem. Of these cases, a majority of victims were passengers while a significant portion were drivers.

In the following years, a master complaint was filed, consolidating hundreds of lawsuits, alleging thousands of sexual assaults since the mid-2010s. The complaint criticizes Driver Inc.’s inadequate safety protocols, including poor driver background checks and limited reporting mechanisms for victims. The complaint also claims Driver Inc. deliberately avoids requiring in-car cameras to maintain swift driver onboarding and preserve its stance that drivers are not employees.

The Engagement Objectives:

1. The company needed to commit to strengthen safety measures to further decrease safety incidents.
2. The company needed to expand disclosures provided in safety reports to cover all markets where the company operates.

Progress on Change

Ongoing Discussions

The company responded to our follow-up outreach efforts in 2025 and shared its 2025 report on governance and stakeholder engagement, which outlines its efforts toward safety. The safety-related section of the report provides an overview of the company's global safety management system, which is based on a 4-pillar framework: safety policy and objectives, safety promotion, safety risk management and safety assurance.

The company also reports investment of time and resources to reduce safety incidents during trips, with a particular focus on preventing sexual misconduct and assault. To enhance trip safety, the company has implemented a range of measures, including regular driver screening, continuous technological innovation, a robust reporting and response system and a commitment to transparency in safety-related disclosures.

In its response, the company also referenced other relevant reports, namely its most recent safety report, dating from the early 2020s and limited to data from the United States. While Driver Inc. claims the issue is continually monitored by its board of directors and management, there is no clear plan to release an updated report or expand coverage to other regions where it operates.

Shareholder and Stewardship Outcomes

In our follow-up with the company, we acknowledged the progress made in both safety reporting and operational safeguards, as well as the recent expansion of Driver Inc.’s safety advisory board. We encouraged the company to consider expanding its safety disclosures to cover all markets and a broader range of incident types, such as attempted assaults, verbal abuse and non-fatal threats. We also inquired about region-specific mechanisms for tracking and responding to safety risks, particularly in geographies with weaker regulatory oversight, and asked whether lessons learned from prior incidents have informed improvements to the global safety strategy. Additionally, we requested further details on upcoming proactive safety measures, including technologies under evaluation, risk mitigation protocols and relevant key performance indicators (KPI) or timelines for implementation.

As of autumn 2025, the company has not responded to our follow-up communication nor agreed to arrange an engagement meeting. The company has taken steps to enhance its safety management system. Although an updated safety report has yet to be published, the company has committed to greater transparency in safety-related disclosures. We will continue to monitor the company’s disclosures and responses for any new developments as part of our ongoing engagement.

Snapshot Two: Encouraging Proactive Disclosures on Unethical Business With a Pharmaceutical Company

Managing Unethical Business Practices

Unethical business practices include, but are not limited to, market manipulation, insider trading, unjustified related-party transactions, breach of intellectual property rights and tax evasion. Similar to corruption and bribery, these practices pose financial and reputational risks including substantial monetary penalties and reputational harm.

We encourage companies to disclose how they proactively manage risks associated with unethical business practices. For instance, in the case of tax evasion risk, companies can have a publicly available tax strategy that outlines their approach to using tax havens, tax incentives and transfer pricing. Other disclosures may include evidence of reasonable steps to determine and follow tax laws, details regarding how tax risks are identified and managed, and whether the company engages with country-by-country reporting.

The Company: Pharma Corp. is engaged in the development and commercialization of medicinal and biopharmaceutical products across several major global markets.

The Issues: The engagement with the company was launched in 2024 following concerns about its approach to managing anticompetitive practices. The company has faced scrutiny over its involvement in various controversies, including price-fixing agreements, delaying the release of generic drugs and misleading marketing tactics. In the early 2020s, the company finalized a nationwide settlement with multiple state-level legal authorities and plaintiffs for alleged deceptive marketing and failure to monitor suspicious orders. In addition, the company has also received significant fines for anticompetitive practices.

On the governance side, the company has a chief compliance and ethics officer who reports to the chief executive officer and has direct access to the board. Its Office of Business Integrity (OBI) is tasked with handling global misconduct reports, including anticompetitive behavior. Reports can be submitted via a whistleblower hotline, and the OBI shares summary information with the board. As such, at the onset of this engagement, the company had a framework to address anticompetitive conduct, yet it appeared to be largely reactive and dependent on whistleblower complaints.

The Engagement Objective: The company needs to disclose how it proactively attempts to identify instances of possible anticompetitive practices.

Progress on Change

Ongoing Discussions

Following our initial outreach in 2024 and subsequent follow-ups in 2025, we held a virtual engagement meeting with Pharma Corp. We discussed its approach to identifying and preventing potential anticompetitive practices. The company confirmed that its compliance committee oversees fair competition practices as per its charter, although this is not clearly reflected in proxy disclosures. The company agreed to review whether antitrust oversight could be made more explicit in future reporting.

It was further shared that the company has a global litigation team with antitrust expertise. This team coordinates with the compliance function to oversee case management, advises business units and handles competition law matters. The team also delivers annual mandatory antitrust training to all employees, with risk-based sessions for higher-risk groups. Internal audits support program improvements, and KPIs on training are reported quarterly to the board. While some enhancements are referenced in its current reporting, the company agreed that more detail on training scope and rationale could be added in future disclosures.

Regarding the monitoring of third-party relationships to manage anticompetitive risks, the company explained its supplier onboarding process. It confirmed that contracts and purchase orders include anticompetition compliance provisions. After our engagement meeting, the company representatives followed up with further details on third-party assessment and due diligence processes. The supplier onboarding process includes due diligence analysis for third party representatives (TPRs) and anti-bribery and anti-corruption clauses in contracts. A dedicated team manages TPR due diligence by assessing risk, overseeing policies, training, and reviewing external reports on misconduct. For higher-risk suppliers, additional actions are taken. A separate team oversees the trade sanction program, regularly screening suppliers for sanctions and conducting checks as needed.

The company welcomed further engagement to clarify outstanding points.

Shareholder and Stewardship Outcomes

It is positive that the company was receptive to feedback and expressed its intent to strengthen disclosures on its proactive measures to identify and prevent potential anticompetitive conduct, including details regarding the governance and oversight of these issues. It also outlined ongoing improvements to training, audits and third-party due diligence and offered to share additional information. Overall, the company demonstrated openness to continued dialogue and committed to improving transparency in future disclosures. We will monitor future disclosures for the improvements discussed and seek continued dialogue as needed.

To learn more about Glass Lewis' active stewardship engagement, see our Q3 report here.‍