Report Feedback Statement 

Include Your Company’s Feedback With Our Research

Request an RFS to Have Your Opinion Heard

Glass Lewis includes your company’s unfiltered opinion on our research with our proxy research reports and delivers it directly to the voting decision makers at every investor client in time for voting decisions to be made or changed.

Request an RFS to Have Your Opinion Heard

The Report Feedback Statement (RFS) is available for all annual and special meetings for companies and shareholder proponents, including transactions and contests. Companies can have their unfiltered opinions included with Glass Lewis research and have the certainty of it being delivered directly into the hands of voting decision makers at investors with $35 trillion in AUM.

Any company that discloses its meeting materials 21 days in advance of the meeting date has up to 7 days to submit an RFS. The cost of the RFS is included in the cost of purchasing Glass Lewis’ research.

Investors are notified immediately when a company’s feedback is available and has been added to a Glass Lewis research report. The company feedback can be accessed from the front page of each report and allows investors to consider that information before they make or change voting decisions ahead of the meeting date.

Why use the RFS?

Companies using the RFS have identified 10 key areas that make the RFS incredibly valuable to them.

  • Global – Available for all annual and special meetings for companies and shareholder proponents, including transactions and contests.
  • Uncontested – Glass Lewis will not edit a company’s feedback or include its own competing statement, maintaining the independence of both parties’ views.
  • Integrated – Company feedback is included with every report for every investor client, enhancing transparency and allowing investors to conveniently and directly compare the opinions of company management to those of Glass Lewis.
  • Delivery – Every investor will be directly notified, emailed and have access to the company’s feedback on Glass Lewis’ voting and research platforms.
  • Voting – Every investor making a vote decision will receive the company’s feedback with the time and ability to still make or change their voting decision.
  • Timing – Companies will be granted up to 7 days to respond, without delaying Glass Lewis’ market leading timeliness of delivering independent research.
  • Accuracy – Glass Lewis will continue to correct any 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 who purchases a specific Glass Lewis report will automatically have the right to submit an RFS 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 company feedback, will be removed so companies have the certainty that every investor has access to the same research report and recommendations.

How to use the RFS?

Any company or shareholder proponent that purchases a Glass Lewis report will now automatically have the right to submit an RFS at no extra cost.

For more information on the RFS or to submit one please contact engagegl@glasslewis.com

Frequently Asked Questions

Download a complete version of the FAQs.

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 unfiltered opinions on Glass Lewis’ research and recommendations. Each RFS is included with Glass Lewis’ research and delivered 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 and engagement team, which will in turn attach each RFS to the relevant research report. Each report is then automatically distributed to all Glass Lewis clients through its research and voting platforms.

Investors are notified immediately when an RFS is available and can access the RFS directly from the front page of each report to quickly inform their voting decisions. These investors represent $35 trillion in AUM and more than 3,000 individual voting decision makers.

Once a report includes an RFS, that will be the only version of the research report available from Glass Lewis, with prior versions removed from distribution. Any clients that have already downloaded an earlier version of the research report will receive an email with the updated research report that includes the RFS.

No. All potential factual errors and omissions identified in a Glass Lewis 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.

No. Engagement with Glass Lewis’ research and engagement teams (email, phone or in-person) is free and subject only to analyst availability.

Engagements can be requested here or by emailing engagegl@glasslewis.com.

In order 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 a Glass Lewis research report for the specific meeting.
  • Have disclosed all relevant documents at least twenty-one (21) days prior to the specific meeting.
  • Have purchased the specific research report directly from Glass Lewis as a company, shareholder proponent, dissident shareholder or party to an M&A transaction.
  • For each specific shareholder proposal discussed in an RFS, the name of the proponent should be clearly identified from publicly available information.
  • Accept the terms and conditions of the RFS.

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 personally identifiable information.
  • Each statement 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.

The deadline for RFS submissions for most meetings is seven (7) days after the Glass Lewis research report has been published, and no later than fourteen (14) days before a company’s 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.

The deadline for RFS submissions for meetings involving a proxy contest, an M&A transaction or a dissident shareholder may be extended to no later than seven (7) days before a company’s meeting, at Glass Lewis’ discretion.

The RFS should be submitted on letterhead, in PDF format.

The use of graphics, charts, bullet points, specific fonts and hyperlinks is at the discretion of each participant.

The purpose of the RFS is to allow participants to more directly express their views and any differences of opinion they may 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.

Any company, shareholder proponent, dissident shareholder or party to an M&A transaction who purchases a specific Glass Lewis report will automatically have the right to submit an RFS at no extra cost.

If the right to an RFS is declined at the time of purchase of a Glass Lewis research report, participation in the RFS may be available at a later date for a fee.

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 an RFS for any reason.  The RFS will be included with Glass Lewis’ research reports immediately after a standard content disclaimer from Glass Lewis.

If, for some reason, an RFS submission fails to comply with the terms and conditions of 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 terms and conditions of the RFS.

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

If a company makes an additional public filing that results in a material revision to Glass Lewis’ 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 needs to be received within two (2) business days following the publication of the revised Glass Lewis research report.

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

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

Further, through Glass Lewis’ free IDR program, companies can check the data used to formulate Glass Lewis’ research reports prior to such reports being published to its clients.

If possible, RFS participants are encouraged to notify Glass Lewis of any potential material errors or omissions as soon as possible, and no later than two (2) business days prior to submission of an RFS so as to allow timely correction and notification to its clients.

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.

Glass Lewis will provide the number of investors who were sent the RFS and the number of investors that viewed or downloaded the underlying research report.

Privacy is a critical component of Glass Lewis’ obligation to its clients. Glass Lewis will never disclose any client-specific information.