Glass Lewis has submitted a comment letter on proposed Revisions to the Principles for Responsible Institutional Investors ≪Japan’s Stewardship Code≫. In particular, Glass Lewis shared comments regarding the new Principle 8, which provides guidance to proxy advisors and other service providers.

As a proxy advisor, Glass Lewis supports the creation of Principle 8. We recognize that the entire market benefits when service providers avoid conflicts and promote transparency, accuracy and active engagement, and we welcome attention to this area. Glass Lewis has spent a lot of time and effort throughout the years to develop policies and procedures, as well as to dedicate resources on initiatives to deal with these very topics. We took the opportunity to share our approach and our experiences, which we believe may provide relevant context to this discussion. We will also highlight areas where we have some concerns regarding the specific guidance that has been proposed.

You can download our submission to the consultation below. For more information, contact