Supporting Effective Investment Stewardship Part One: Empowering Customized Voting and Engagement With Glass Lewis

This article is the first in a three-part series on Supporting Effective Investment Stewardship. The series explores how Glass Lewis helps investors strengthen their stewardship programs.

In Part One, we focus on how investors can prioritize engagement opportunities and align activities with voting priorities. We also explore how they can strengthen their stewardship strategy with Glass Lewis’ custom policy development and custom engagement campaigns.

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Streamlining Stewardship With Targeted Support

Effective stewardship reflects each investor’s unique profile, exposure, and investment strategy – whether assets are managed internally or through external managers.

Specialized support can help investors extend their reach and focus more on high-value engagement activities, such as setting priorities and engaging with companies directly. Outsourced stewardship programs can streamline processes and optimize resources across key activities such as issue identification, company engagement, and progress monitoring.

Identifying Priorities for Engagement  

Before setting priorities, investors typically establish robust due diligence and monitoring frameworks to guide their stewardship approach. Credible stewardship emphasizes the quality of engagements over quantity, and their potential to achieve meaningful results.

A deliberate, well-prioritized approach helps maximize impact, optimize resources, and strengthens alignment between stewardship activities and investment goals. For investors managing broad, well-diversified portfolios, stewardship priorities often involve balancing idiosyncratic and systemic considerations.

Common criteria for prioritizing engagements include:

• Alignment with stewardship or responsible investment policies
• Client or beneficiary topic interests
• Ownership levels and portfolio exposure
• ESG benchmarks (e.g., risk scores and ratings, or norms breaches)
• AGM-related considerations
• Credit quality or bond terms
• Alignment with voluntary and mandatory frameworks (e.g., SDGs, SFDR, ISSB)
• Sectors, themes or geography (e.g., emerging markets)
• Investor collaborations and policy advocacy

Under regulations such as the EU’s Shareholder Rights Directive II (SRD II), investors are expected to disclose their voting behavior, significant votes, and use of proxy advisors. Investors often apply vote-specific criteria to help determine where deeper intervention is warranted, including compliance aspects, ownership levels, contentious or high-profile votes, and insights gained from engagement dialogues.

Aligning engagement priorities with voting efforts fosters greater consistency and credibility in stewardship practices – ultimately reinforcing long-term value for clients and beneficiaries.

Glass Lewis’ Custom Approach

Implementing a Custom Voting Policy

Glass Lewis partners with investors to translate their stewardship priorities into custom voting policies that reflect their firm’s values and strategic investment objectives.

Developing and implementing a custom voting policy takes one to six weeks, depending on complexity, following a defined process that ensures transparency and alignment.

Step 1: Defining the Landscape

• Policy team works to understand your stewardship objectives, evaluate your coverage universe and regulatory requirements, and review industry best-practices.

Step 2: Review the Existing Policy​

• Policy analysts assess overlap with applied policy, compare with peers, and outline updates to reflect current trends and needs.

Step 3: Build and Implement New Policy

• Dedicated policy team codifies your policy in our rules-based engine for your review.
• All changes are peer-reviewed, tested, and logged in internal change management tool.

Step 4: Go Live

• Following review and feedback, we implement your policy in our Viewpoint proxy voting platform.

Step 5: Monitor and Report on Outcomes

• Policy changes are monitored including auditing of a subset of recommendations.
• Outcome reporting includes data on policy outcomes in Viewpoint, KPI reports on recommendation accuracy, and annual guideline review.

Within this framework, investors can flag specific votes for review, apply voting review thresholds (e.g., based on ownership levels or vote decisions), and receive alerts on contentious issues.

“Glass Lewis’ Custom Policy service ensures investors can operationalize their stewardship beliefs through a rigorous and practical approach, enabling them to vote with consistency and conviction. It allows you to move beyond ‘off-the-shelf’ policies to build a voting framework aligned with your investment philosophy, risk appetite, and fiduciary responsibilities.”
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- David Cunnane, Manager, Client Policy Europe

Leveraging Custom Engagement Services

For investors seeking to expand their engagement efforts without adding internal resources, Glass Lewis offers fully customized engagement campaigns tied to specific themes or driven by voting priorities.

Our stewardship team collaborates with each client to set the strategy and priorities, identify targets, and execute engagements aligned with key themes such as climate risk, board effectiveness, or human rights.

Each engagement campaign is built around four pillars:

• Client-led priorities: Shaped by each client’s goals and market drivers, focus themes are defined collaboratively at the outset.
• ‍Data-driven insights: Drawing on client data, proprietary ESG datasets and risk assessments, and portfolio exposures, Glass Lewis identifies high-impact engagement opportunities.
• ‍Strategic alignment: Focus lists are refined to balance geography, company size, and feasibility, ensuring that each campaign is both actionable and effective.
• ‍Corporate access: Clients benefit from Glass Lewis’ extensive corporate access network, with the option to participate directly in engagement dialogues.

For vote-driven engagement campaigns, Glass Lewis customizes the the company engagement selection criteria based on client preference (e.g., based on votes against management defined by a client’s custom policy).

Glass Lewis coordinates with the client to tailor the outreach process, including the template, criteria, and letter content (such as vote decision and rationale), and escalation process. Investors who use Glass Lewis for proxy voting benefit from an integrated letter-sending process through the Viewpoint platform.

For each target company, Glass Lewis’ Stewardship Team builds a comprehensive outreach strategy including tailored engagement objectives, risk benchmarks, and structured questions to guide dialogue.

Activities, progress and outcomes are tracked in real time through the Engagement Management Platform, providing transparency to clients and insights to support stewardship reporting.

“By combining investor priorities with our expertise, we help clients build and scale engagement programs. Guided by a proven process and an experienced team, we focus on raising awareness and driving meaningful change.”
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- Elena Leofanti, Senior Director, Investment Stewardship

Conclusion

Determining which companies to engage and how to vote is only one part of an effective stewardship strategy. Executing on those priorities should involve an integrated approach of practices, informative progress monitoring over time, and transparent reporting of outcomes back to stakeholders.

With over two decades of stewardship expertise, Glass Lewis empowers investors to strengthen their stewardship programs through tailored policies, customized engagement services, and technology designed to support stewardship workflows.

In the upcoming articles of this series, we’ll examine how to scale engagement efficiently using Glass Lewis’ platforms and services, and how to streamline stewardship reporting through integrated data and technology – enabling investors to achieve greater impact with less effort.