Following the SEC’s proposed rules on proxy advisory firms, Glass Lewis has announced that “unedited company feedback on its research will now be included with all its proxy research papers and delivered directly to the voting decision makers at every investor client.” The approach Glass Lewis is taking is consistent with the Center On Executive Compensation’s 2018 recommendations to the SEC (which were ultimately included in the Commission’s proposed proxy advisory firm rules) and were based on multiple subscriber examples of not being able to address problematic reports.
According to the release, companies will have up to seven days to provide Glass Lewis with feedback on their proxy report. Glass Lewis will republish the report with the company’s feedback and will notify investors that the feedback is available. Investors will be able to locate the feedback on the frontpage of the republished report.
- The feedback option will be available globally, for all companies and shareholder proponents, for all annual and special meetings.
- Glass Lewis will not edit any responses or respond to company feedback.
- Company feedback will be provided to investors with enough time to change voting decisions.
It appears that companies will need to purchase their report in order to have the right to submit feedback. Further, while the move appears designed to get out in front of the rule, it does not include information on company’s ability to fact-check and correct reports prior to publication.