Due Diligence Resources
Due Diligence Resources
Glass Lewis understands the importance of due diligence when engaging and retaining a proxy advisory firm. The following resources are intended to assist our clients and prospective clients in fulfilling their proxy voting responsibilities.
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Complying with the SEC Proxy Advisor Guidance
This summary helps map existing Glass Lewis policies and procedures to the SEC Guidance Regarding Proxy Voting Responsibilities of Investment Advisers and the use of Proxy Advisory firms.
Conflict of Interest Policies and Procedures
Glass Lewis takes all appropriate steps to prevent, identify, and manage circumstances that may give rise to potential, perceived or actual conflicts of interest. Glass Lewis’ Policies and Procedures for Managing and Disclosing Conflicts of Interest outline the mechanisms in place to identify, mitigate, and disclose potential conflicts.
Code of Ethics
Glass Lewis’ Code of Ethics sets forth Glass Lewis’ commitment to ensure all individuals acting on its behalf fully comply with all laws, regulations, standards of care, ethical business practices, as well as the basic standards expected in the workplace. It also contains policies on personal securities trading, external engagement with issuers and interested parties, and the disclosure of personal interests and/or control positions involving a listed company.
Modern Slavery Act Statement
Glass Lewis prides itself on its reputation for conducting business activities in the highest ethical and professional manner and does not tolerate modern slavery in its business or supply chains, taking effective steps to meet this commitment.
Foreign Corrupt Practices Act Policy
Glass Lewis is committed to the highest standards of honesty, propriety and integrity in all of its activities. Fraud of any kind is strictly forbidden.
A zero-tolerance approach is applied to bribery and corruption at every level of Glass Lewis’ business. Glass Lewis complies with all anti-corruption laws where it does business, including but not limited to the U.S. Foreign Corrupt Practices Act (the “FCPA”) and the UK Bribery Act 2010 (the “UK Bribery Act”).
DownloadAnti-Money Laundering and OFAC Policy
Glass Lewis will not knowingly engage in financial transactions that involve proceeds from an unlawful activity or that support terrorist activities, nor will Glass Lewis engage in financial transactions with individuals, entities and restricted countries designated by The U.S. Department of the Treasury Office of Foreign Assets Control (OFAC) or similar sanctions regulations in other countries where Glass Lewis does business.
Sustainability Policy
Glass Lewis believes it is in the best interest of our organization, employees, clients and society in general, to move along a path toward sustainability by promoting and practicing social, economic and environmental responsibility. Glass Lewis’ path to sustainability is two-fold: we promote sustainability both in the marketplace through our customer solutions and in our own operations. This Sustainability Policy outlines the material areas, objectives, and practices that make up our two-fold path to sustainability.
UK FCA Proxy Advisor Official List
Glass Lewis and its UK-based subsidiary, GL & M UK Ltd., are registered with the Financial Conduct Authority as proxy advisors, as required by The Proxy Advisors (Shareholders’ Rights) Regulations 2019.
How Europe’s Boards Are Overseeing and Disclosing on AI in 2026
This article explains how European large-cap companies have significantly expanded their disclosure and oversight around the governance of AI technologies.
How Europe’s Boards Are Overseeing and Disclosing on AI in 2026
This article explains how European large-cap companies have significantly expanded their disclosure and oversight around the governance of AI technologies.
Modernizing Spain’s Corporate Governance Framework: CNMV’s Plan 2030
This article discusses the CNMV's Plan 2030, intended to strengthen the Spanish capital market, protect investors and modernize the CNMV itself.
Modernizing Spain’s Corporate Governance Framework: CNMV’s Plan 2030
This article discusses the CNMV's Plan 2030, intended to strengthen the Spanish capital market, protect investors and modernize the CNMV itself.
Assessing Shareholder Vote Risks: An Overview of Four Key Challenges for Public Companies
This article outlines how challenges surrounding shareholder voting risk extend beyond the likelihood of a proposal passing or failing, and how a more structured approach to assessing investor signals can support earlier engagement, clearer board reporting, and more informed governance decisions.
Assessing Shareholder Vote Risks: An Overview of Four Key Challenges for Public Companies
This article outlines how challenges surrounding shareholder voting risk extend beyond the likelihood of a proposal passing or failing, and how a more structured approach to assessing investor signals can support earlier engagement, clearer board reporting, and more informed governance decisions.
How Companies and Investors Can Navigate Japan's Revised Corporate Governance Code
This article helps investors navigate Japan's 2026 updated Corporate Governance Code by mapping its requirements to Glass Lewis solutions.
How Companies and Investors Can Navigate Japan's Revised Corporate Governance Code
This article helps investors navigate Japan's 2026 updated Corporate Governance Code by mapping its requirements to Glass Lewis solutions.