ISS announced June 17, 2015 it has begun its semi-annual peer group construction process for Russell 3000 companies. Russell 3000 companies having meetings between September 16, 2015 and January 31, 2016 may submit the peer group that will be disclosed in the proxy for such meeting used for CEO benchmarking purposes by 8 pm Eastern on Friday, July 10, 2015.
Companies that have not made any changes to their proxy-disclosed peer group or that do not wish to provide such information in advance, do not have to participate.
Starting June 29, 2015, companies can submit their peer groups using the web form available at:
http://www.issgovernance.com/u-s-company-peer-group-feedback
Companies will also have to submit a confirmation letter on company letterhead, submitted using an email address that is from the company’s email domain of the company’s contact.
ISS wants companies to note the following (from Friday’s ISS announcement):
- The peer group provided should be the peer group used for benchmarking CEO pay for the fiscal year ending prior to your next annual meeting.
- If your annual meeting is after January 31, 2016, no action is required as ISS will conduct a separate peer submission process for these companies in late-2015.
- While public disclosure of this information is not required, our expectation is that the same peers provided via this form will be disclosed in the upcoming proxy. Significant differences between submitted peers and peers cited in the 2015 proxy for 2014 pay may cause ISS to re-run the peer group and may result in the company not being able to pre-submit peers in future years.
- The ISS research team will use this information only for the purpose of constructing peer groups.
- Submissions should include your complete peer list, selected through the lookup tool provided.
- Please do not make multiple submissions or submit information other than relevant peers, as this may disrupt accurate submission of your peers.
- Important: Following submission of the online form, you will need to confirm your submission by sending ISS an electronic copy (scanned PDF or equivalent) of the submitted list on your company’s letterhead along with your name, email address and company name, to peerfeedback@issgovernance.com. The confirmation email must be from the email domain of the company contact, in order to confirm that the submission was made by an authorized party. Detailed instructions for this confirmation step are provided online as part of the submission process.
- Feedback and confirmation letters must be submitted no later than 8PM EDT on Friday, July 10, 2015.
- Note that, as in prior years, ISS peer groups are not finalized until our research is published.
FAQs about ISS’s peer group methodology are set out in, 2015 U.S. Proxy Voting Policies and Procedures–Frequently Asked Questions on Peer Group Selection Methodology, which can be found at:
http://www.issgovernance.com/file/faq/us-peer-group-feedback-faq.pdf