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.
Podcast | Activist Investing Today: Glass Lewis' Timmer on AI, Future of Governance
Glass Lewis president Diederik Timmer discusses the role of AI in proxy advisory services, evolving shareholder voting practices and the firm's customized voting policies.
Podcast | Activist Investing Today: Glass Lewis' Timmer on AI, Future of Governance
Glass Lewis president Diederik Timmer discusses the role of AI in proxy advisory services, evolving shareholder voting practices and the firm's customized voting policies.
The Most Advanced AI Model Can Also Be the Most Fragile: A Lesson for Investment Stewardship
This article examines how the sudden withdrawal of a frontier AI model underscores the importance of trusted data, domain expertise, and human oversight in building resilient investment stewardship workflows.
The Most Advanced AI Model Can Also Be the Most Fragile: A Lesson for Investment Stewardship
This article examines how the sudden withdrawal of a frontier AI model underscores the importance of trusted data, domain expertise, and human oversight in building resilient investment stewardship workflows.
On the Agenda: Five Questions Answered on Climate Intelligence Research
This interview with Emil Moldovan, Head of Climate Science, sheds light on the development process and methodology behind Glass Lewis’ Climate Intelligence Research.
On the Agenda: Five Questions Answered on Climate Intelligence Research
This interview with Emil Moldovan, Head of Climate Science, sheds light on the development process and methodology behind Glass Lewis’ Climate Intelligence Research.
The Foundation Matters More Than the Model: Why Trusted Data and Human-Centric AI Will Define the Next Era of Investment Stewardship
This white paper explains why durable value will come from trusted proprietary data, rigorous governance, and human oversight that make AI outputs reliable enough for institutional decision-making.
The Foundation Matters More Than the Model: Why Trusted Data and Human-Centric AI Will Define the Next Era of Investment Stewardship
This white paper explains why durable value will come from trusted proprietary data, rigorous governance, and human oversight that make AI outputs reliable enough for institutional decision-making.