Frequently Asked Questions

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Questions related to Glass Lewis’ interactions with corporate issuers.

Yes. Glass Lewis research analysts will hold meetings with issuers and other stakeholders, outside of certain restricted periods discussed below, based on inbound requests with detailed agendas. Glass Lewis, through the Issuer Relations team, may also invite companies to meet with research analysts to discuss specific topics related to recent or upcoming shareholder meetings.

Meetings with Glass Lewis’ research analysts focus on Glass Lewis policies and methodologies, and participants’ respective views on governance practices.

Glass Lewis research analysts are open to constructive dialogue with companies and other stakeholders; however, our research and recommendations are based solely on publicly available information.

We maintain our independence by refraining from providing previews of our recommendations and by making no guarantees about the concerns we might raise in our research. Additionally, we do not review or comment on draft versions of proposed proxy materials.

We encourage issuers to publicly disclose information that could be deemed material and will not consider any non-public information in our research. This approach ensures that shareholders have access to all relevant information and are fully empowered to make informed voting decisions, while minimizing potential conflicts of interest. Before meeting with Glass Lewis, corporate issuers representatives must agree, among other things, to not share any non-public information, material or otherwise, with Glass Lewis research analysts as part of a meeting or other communications.

No. While we make efforts to accommodate meeting requests, Glass Lewis makes no guarantees and accepting meetings is at the discretion of the Glass Lewis research team.

We encourage issuers, their representatives, and any other stakeholder who wish to meet with our analysts to submit detailed agendas for consideration. Meetings are arranged based on our research team’s availability, our issuer relations procedures, and whether the dialogue will assist us when producing Proxy Paper research for our clients.

No. There is no cost to meet with Glass Lewis research analysts.

To request a meeting with Glass Lewis, please complete the appropriate form, via our website. Once received, the Issuer Relations team will liaise with our research analysts regarding the opportunity. We endeavor to respond within two business days from receipt of the request.

The period available to meet with Glass Lewis research analysts depends on the type of shareholder meeting you wish to discuss. We recommend that interested parties reach out early to request a meeting.

Below are the distinct types of meetings available to issuers, arranged by our Issuer Relations team:

Uncontested shareholder meetings: Requests pertaining to routine meetings are only accepted before the publication of shareholder meeting materials (including preliminary), based on capacity and where detailed agendas are provided. We cannot accept meetings during each market’s proxy season, when timely research for our clients is the top priority. Meetings can be requested here.

E&S shareholder proponents or related activism: Shareholder proponents & subject companies can engage after the proposal is submitted and before the company in question files its proxy statement. Requests are considered during proxy season, outside of the solicitation period. Meetings can be requested here.

Contested or M&A shareholder meetings: Requests pertaining to contested meetings or M&A transactions will only be considered after meeting filings are made public. When engaging with an issuer or shareholder about a contested situation, Glass Lewis offers opposing parties a similar opportunity to present their views. Meetings can be requested here.

Please read our Engagement Meeting Terms and Conditions here.

Yes. Glass Lewis discloses meetings with issuers and other stakeholders in the Proxy Papers written on the subject company, for one year following the meeting date. Details disclosed include: the party Glass Lewis engaged with, the date of the meeting, the meeting organizer, the type of meeting (virtual/in-person), and the topics discussed with the issuer.

Glass Lewis offers alternative ways to connect with research analysts, outside of formal meetings. These forms of communication are also permitted during the solicitation period and/or proxy season.

Questions for Research 

Glass Lewis research analysts are open to answering questions related to market-specific policy guidelines. We aim to respond within three business days; responses are sent by the Glass Lewis Issuer Relations team. Responses will aim to provide clarity on Glass Lewis’ approach and specific related policies. However, Glass Lewis will not provide any preview or guarantees related to future analysis or voting recommendations. Glass Lewis research is solely based on publicly available information and all meeting proposals are reviewed on a case-by-case basis. Questions may be submitted via our online form.

Shareholder Communications 

Glass Lewis welcomes publicly available shareholder communications, letters, presentations, documents and filings from issuers, their representatives, and shareholders. Supplemental filings shared during the solicitation period and after the publication of our Proxy Paper will be reviewed by research analysts to determine whether the information is materially relevant for clients. If there is sufficient time before the voting deadline, we may republish our research with the latest information. Any updates due to additional disclosure will be clearly highlighted in our research. Remuneration letters, investor slide decks, annual updates, shareholder communications or filings can be submitted via our online form.

Yes. See our website for the full range of resources and services available for issuers, including access to our Proxy Paper research via the Governance Hub.

Glass Lewis does not share drafts of its Proxy Papers with issuers or other interested parties, but issuers listed in in North America, Europe, Israel, South Africa, Japan, Malaysia, Singapore, and India, can register for our complimentary Issuer Data Report (IDR) program to verify the underlying data used by Glass Lewis research analysts before the publication of their respective Proxy Paper.

Issuers must complete a one-time registration to participate in this program. The IDR is only guaranteed where the issuer is listed in one of the markets above and when their meeting documents are disclosed at least 30 days prior to their annual general meeting (AGM).

More information and FAQs related to the IDR program can be found on our website.

We value having timely and accurate research available for our clients. If you believe there is a factual error related to your company’s proxy paper report, this should be notified to us immediately via this form. Supplemental filings made during the solicitation period can be shared with Glass Lewis via our online form.

Through Glass Lewis’ Report Feedback Statement (“RFS”) program, companies, shareholder proponents, dissident shareholders and parties to an M&A transaction that purchase our Proxy Papers can opt to have a statement responding to our research transmitted to our customers through our research and voting platforms. The Report Feedback Statement (RFS) is available for all annual and special meetings, including transactions and contests. You may request to purchase Proxy Paper research reports and the RFS via this form.

Glass Lewis Proxy Papers can be purchased directly from Glass Lewis and are available for issuers via the Governance Hub. Our Proxy Paper research reports contain ESG data and scores, compensation data, board details, and highly nuanced custom analysis provided by our seasoned team of research analysts and subject matter experts. To learn more, request an introductory call with a member of our corporate business team.

Generally, no. Proxy Papers are for our clients’ internal business use only, are the intellectual property of Glass Lewis, must be purchased directly from Glass Lewis, and cannot be shared by or with third parties without Glass Lewis’ express permission. In most circumstances, however, and with our review and approval, Glass Lewis clients that purchase our Report Feedback Statement (“RFS”) service may share minimal portions of our analysis in a press release or similar communication.

Additional questions related to Glass Lewis Proxy Paper research reports.

We use only publicly available information. This includes company filings, press releases, news articles and any other material that is available to all shareholders. We do this to ensure our analysis is fair and objective and to help encourage companies to release all necessary information to their shareholders.
We would be happy to have a conference call/meeting with you to discuss general corporate governance issues. Please visit our Engagement Policy page to submit a request detailing your availability, topics of interest and date of your last shareholder meeting.
Please visit our Purchase a Proxy Paper page to submit a request for a copy of your company’s Proxy Paper research report.

We receive the company information in our reports from a third party data provider – Capital IQ. If the information we provide is not up to date, we encourage you to contact them directly.

The percentages are annualized shareholder returns based on the “Closing Price” date that appears on page 3 of the Glass Lewis report in the Competitors/Peer Comparison. All of the market-based data on pages 2 and 3 of our reports (stock chart, total return table, market cap, enterprise value, closing price, stock performance) are as of that date that corresponds to our most recent data download from our third-party provider, Capital IQ, prior to publishing the report.

For reports on companies that include our pay-for-performance analysis, we generally display a subset of companies from the pay-for-performance sub-industry peer group. For reports on companies that do not include our pay-for-performance analysis, the companies shown on page 3 are selected based on GICS, market cap and revenue.

The data on page 3 is as of the “Closing Price” date listed on that page. The analysis of the equity plan proposal is as of the company’s fiscal year-end date.

We classify a director as affiliated when the director has a material financial, familial or other relationship with the company or its executives but is not an employee of the company. This includes directors whose employers have a material financial relationship with the company. In addition, we view a director who owns or controls 20 percent or more of the company’s voting stock as an affiliate.
We apply different financial thresholds for different types of related-party transactions. Where no amount is disclosed, we assume the transaction surpasses our applicable threshold. The strictest threshold is applied to situations in which a director (or a family member) is paid for a service he or she agreed to perform for the company, outside of his or her service as a director, including professional or other services. Our next threshold applies to situations where a director (or a family member) is employed by a professional services firm such as a law firm, investment bank or consulting firm and the company pays the firm, not the individual, for services. This threshold would also apply to charitable contributions to schools where a director (or a family member) is a professor, or charities where a director (or a family member) serves on the board or is an executive, and any aircraft or real estate dealings between the company and a director’s firm. Lastly, we apply our most lenient threshold to all other business relationships where a director (or a family member) is an executive officer of a company that provides products/services to or receives products/services from the company.
We apply a 5-year look-back period to former company employees and a 3-year look-back period to related-party transactions other than interlocking directorships and charitable contributions, for which we generally do not apply a look-back period.