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. 

Any additional compliance-related queries can be directed to compliance@glasslewis.com.

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 issued on August 21, 2019.

Download

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.

Download

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.

Download

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.

Download

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.

Download

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.

Download

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. This summary provides an outline of Glass Lewis’ approach with regards to Community Impact, Diversity & Inclusion, Responsible Governance, and Environmental Practices.

Download