Report Feedback Statement 

Include your company’s feedback with our Proxy Paper research. Feedback statements are addressed directly to shareholders, allowing you to share your opinions on our research with the voting decision-makers at every investor client in time for voting decisions to be made or changed.

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Request an RFS to Have Your Opinion Heard

The Report Feedback Statement (RFS) is available for all annual and special meetings, including transactions and contests, for companies and shareholder proponents. Companies can have their unfiltered opinions included with Glass Lewis’ research and have the certainty of it being delivered directly into the hands of institutional investor decision-makers with $40 trillion in AUM.

When purchasing Glass Lewis’ research as a company, shareholder proponent, dissident shareholder, or party to an M&A transaction, such as through a subscription to our Governance Hub platform, the RFS is included in the cost of the research. Institutional investors and intermediaries interested in submitting an RFS must purchase the underlying report for an additional fee, separate from their research-only or Viewpoint subscription, which includes the right to submit the RFS. You may request to purchase Proxy Paper research reports and the RFS here.

The RFS can be accessed from the front page of each Proxy Paper research report and allows investors to consider that information in time to make or change voting decisions ahead of the meeting date. Clients that have previously downloaded the Proxy Paper research report are notified directly by email when the RFS is available and has been added to such report. Previous versions of the report, without the RFS, will no longer be available on Viewpoint or any other Glass Lewis platforms.

Why use the RFS?

There are 10 key areas that make the RFS incredibly valuable as a shareholder engagement tool:

  • Global – Available for all annual and special meetings, including transactions and contests, for companies and shareholder proponents.
  • Unfiltered* – Glass Lewis will not edit feedback to maintain the independence of both parties’ views.
  • Integrated – Included with the Proxy Paper research report, enhancing transparency and allowing investors to conveniently compare the opinions of company management or shareholder proponents directly to those of Glass Lewis.
  • Delivery – Every client that previously accessed the report will be directly notified and emailed the updated report. All clients have access to the updated report with the RFS on Glass Lewis’ voting and research platforms.
  • Voting – Every client making a voting decision will receive the company’s feedback with sufficient time in advance of their ability to make or change their voting decisions.
  • Timing – The RFS can be submitted up to 14 days before the shareholder meeting date (and in the case of contested or M&A-related meetings, up to 7 days before the shareholder meeting date), without delaying Glass Lewis’ market-leading research delivery times.
  • Accuracy – Glass Lewis will continue to correct factual errors found in its research, including when a company is unable to pre-screen the data used by Glass Lewis.
  • Cost – Any company or shareholder proponent that purchases the Proxy Paper research report for a shareholder meeting in which they are directly involved can submit an RFS for that meeting at no extra cost.
  • Engagement – Companies and investors will be equally informed, saving them precious time and resources by no longer having to include specific discussions of Glass Lewis’ research in their private engagements.
  • Consistency – Prior research reports, without the RFS, will be removed from Glass Lewis’ research and voting platforms to ensure every Glass Lewis client has access to the same research report and recommendations.

* Glass Lewis will review each RFS submission for compliance with the RFS requirements and guidelines (as set forth in the “Frequently Asked Questions” below), may request updates to the RFS submission to comply with those requirements and guidelines, and may refuse to publish an RFS that does not comply with the RFS requirements and guidelines. Where Glass Lewis requests the correction of a factual error, or the clarification of a factual statement, and such request is not honored, Glass Lewis may choose to publish the RFS together with its own corrective or clarifying statement.

Here are some of the ways participants have leveraged the RFS:

  • Provide additional context for details included in public filings that may have informed the board’s decision-making.
  • Express a difference of perspective or opinion with Glass Lewis’ analysis and recommendations.
  • Reply to shareholder proposals and highlight important information from the company’s disclosure to ensure investors do not miss it.
  • Reinforce Glass Lewis’ analysis and vote recommendations, especially where that analysis and/or recommendation aligns with the board’s approach.
  • Address portions of the Proxy Paper research report that do not directly factor into Glass Lewis’ recommendations, such as ESG Risk Ratings or additional compensation analytics from our data partners.

Frequently Asked Questions

The Report Feedback Statement (RFS) allows companies, shareholder proponents, dissident shareholders, and parties to an M&A transaction to directly express their differences, agreements, and opinions on Glass Lewis’ research and recommendations. Each RFS is included with Glass Lewis’ research and made available to the voting decision-makers at every investor client.

All sides alike are eligible to participate and will provide their RFS directly to Glass Lewis’ research team, via our online submission form, who will in turn attach each RFS to the relevant Proxy Paper research report. The RFS will then be distributed to all Glass Lewis clients through its research and voting platforms.

Clients that previously downloaded the Proxy Paper research report are notified immediately by email when an RFS is available and can quickly access the RFS directly from the front page of the report. These investors represent $40 trillion in AUM and more than 3,000 individual voting decision-makers.

Once a Proxy Paper research report includes the RFS, that is the only version of the report available from Glass Lewis and prior versions are removed from distribution.

No. All potential factual errors and omissions identified in a Proxy Paper research report can and should be reported here, as soon as possible.

Companies can also participate in Glass Lewis’ free Issuer Data Report program (IDR) to check the data used by Glass Lewis to formulate its analyses and recommendations, prior to the relevant research report being published to its clients.

Companies interested in registering for the IDR can submit a request here, but please note that the IDR is not available in all markets and a list of participating markets can be found at the link above.

No, there is no cost to engage with Glass Lewis’ research and engagement teams (by email, phone or in-person). Scheduling an engagement meeting is, however, subject to analyst availability and only permitted during the times outlined in Glass Lewis’ Engagement Policy.

To learn more about engaging with Glass Lewis, please visit the Engagement page of our website here.

To be eligible to submit an RFS, all criteria below must be satisfied.

  • Be a company, shareholder proponent, dissident shareholder or party to an M&A transaction clearly identified in or covered by Glass Lewis’ research for the specific meeting.
  • Have disclosed all relevant documents at least 21 days prior to the specific meeting.
  • Have purchased the specific Proxy Paper research report directly from Glass Lewis as a company, shareholder proponent, dissident shareholder, or party to an M&A transaction, and not as an institutional investor or intermediary through a research-only or Viewpoint subscription. Proxy Paper research reports can be purchased here.
  • For each specific shareholder proposal discussed in an RFS, the name of the proponent should be clearly identified from publicly available information.
  • Submit the RFS no later than 14 days before the related shareholder meeting. Provided, however, that RFS submissions for meetings involving a proxy contest, an M&A transaction, or a dissident shareholder may be extended to no later than 7 days before the related shareholder meeting, at Glass Lewis’ discretion.
  • Accept the terms and conditions of the RFS.

The RFS provides you with the opportunity to speak directly to company shareholders and should be addressed directly to these shareholders (e.g., Dear Shareholders, Dear Owners, Fellow Shareholders). Please do not address the RFS to Glass Lewis or its research analysts.

Yes. All RFS participants must ensure the following prior to delivering their RFS to Glass Lewis.

  • The participant has consulted with legal counsel to ensure the submission of its RFS complies with all laws and regulatory requirements applicable to the participant and its disclosure of information.
  • The information disclosed in the RFS is “publicly available” information, meaning the information has been disseminated in a manner making it available to investors generally.
  • A good faith effort has been made to ensure that all the information contained in the RFS is accurate.
  • None of the statements included in the RFS defame or disparage Glass Lewis, its subsidiaries, owners, and employees, or any third party. Glass Lewis also expects RFS participants to exercise professionalism and civility in their responses, including refraining from comments that are not relevant to the RFS and not including any unnecessary personal names or other personal data.
  • The RFS must be signed by an executive at the organization authorized to submit the RFS on behalf of such organization and should feature contact information to enable investors to follow up with the organization.

Glass Lewis may refuse to publish an RFS that does not comply with these guidelines, such as an RFS that Glass Lewis reasonably believes violates any laws or regulatory requirements, is defamatory or disparaging, unnecessarily includes any personal data, or is not signed by an executive with authority to submit the RFS. Glass Lewis may allow the RFS participant to submit a revised RFS, provided there is enough time for publication and the resubmission complies with the requirements and guidelines of the RFS.

Additionally, Glass Lewis may request the correction of a factual error or the clarification of a factual statement and, if such request is not honored, Glass Lewis may publish its own corrective or clarifying statement.

RFS submissions must be made no later than 14 days before the related shareholder meeting. As a reminder, all alleged material factual errors should continue to be brought to the attention of Glass Lewis, as soon as possible, to allow timely correction and notification to its clients.

RFS submissions for meetings involving a proxy contest, an M&A transaction, or a dissident shareholder may be extended to no later than 7 days before a the related shareholder meeting, at Glass Lewis’ discretion.

  • The RFS must be submitted on company letterhead and in PDF format.
  • The use of graphics, charts, bullet points, specific fonts and hyperlinks is at the discretion of each participant.
  • Submissions should be addressed to “Shareholders” or “Fellow Shareholders”, not to Glass Lewis.
  • All statements must be signed by an authorized signatory (electronic signature is acceptable).

The purpose of the RFS is to allow participants to directly express their views and any differences of opinion they have with Glass Lewis’ research and recommendations.

The RFS is not intended to be a forum to evaluate or critique other firms, but citing other firms and their work is permissible if it is relevant to the views and opinions expressed in an RFS.

In accordance with the requirements outline above, when purchasing a Proxy Paper research report as a company, shareholder proponent, dissident shareholder, or party to an M&A transaction, including subscriptions to the Glass Lewis Governance Hub platform, the cost of the report includes the RFS. Institutional investors and intermediaries interested in submitting an RFS must purchase the underlying report for an additional fee, separate from their research-only or Viewpoint subscription, which includes the right to submit the RFS.

Glass Lewis’ research reports can be purchased here.

No. The RFS is the participant’s opportunity to make a statement of its views and Glass Lewis will not edit or alter the statement.

Please note, however, that Glass Lewis will review each RFS submission for compliance with the RFS requirements and guidelines. If, for some reason, an RFS submission fails to comply with the requirements and guidelines for the RFS, Glass Lewis reserves the right to reject the RFS and may allow the RFS participant to submit a revised RFS, provided there is enough time for publication and the resubmission complies with the requirements and guidelines of the RFS.

Additionally, where Glass Lewis requests the correction of a factual error, or the clarification of a factual statement, and such request is not honored by the RFS participant, Glass Lewis may choose to publish the RFS together with Glass Lewis’ own corrective or clarifying statement.

RFS participants are permitted to submit one RFS per shareholder meeting.

If additional public filings result in a material revision to the Proxy Paper research report, an RFS participant will be permitted, at Glass Lewis’ discretion, to submit an additional RFS, for a nominal distribution fee. This second RFS must be submitted within 2 business days following the publication of the revised Glass Lewis research.

Once a valid error or omission is reported, Glass Lewis will update the relevant Proxy Paper research report and republish it to clients with a note describing the changes.

To be clear, Glass Lewis does not charge any fees for resolving factual issues. The purpose of the RFS is to address differences of opinion, not to charge for resolving factual errors or omissions.

Further, through Glass Lewis’ IDR program, companies can check the data used to formulate Glass Lewis’ research, at no cost, prior to the applicable Proxy Paper research reports being published to Glass Lewis’ clients.

If possible, RFS participants are encouraged to notify Glass Lewis of any material factual errors or omissions as soon as possible, and no later than 2 business days prior to submission of an RFS to allow adequate time for correction and notification of Glass Lewis’ clients.

No, the RFS process occurs after the publication of Glass Lewis’ research and recommendations and before the deadline for client investors to make or change their voting decisions has expired.

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