ISS announced that the window period for public companies to submit updates for their peer groups is open and will close at 8 pm Eastern on December 9, 2016.
The peer group submissions are now handled through ISS Corporate Solutions’ Governance Analytics website. Only companies (issuers) may submit their peer groups to ISS.
What peer companies is ISS seeking? Those that were used to set pay that is required to be covered in the next proxy to be filed. For example, for calendar-year companies, their 2017 proxies will cover 2016 pay and pay decisions. Therefore, ISS is seeking the peer group used for setting/considering 2016 pay, not the peer group used for setting/considering 2017 pay (which would be required to be disclosed in the 2018 proxy). If a company has not made any changes to its 2016 peer group compared to its 2015 peer group, it does not have to submit anything to ISS. If a company has made changes to its 2016 peer group, it should seriously consider submitting this peer group to ISS during the window period to ensure that the 2017 ISS proxy report accurately reflects the company’s 2016 peer group as disclosed in the proxy. Failure to submit an updated peer group for 2016 will mean that ISS will likely use the company’s 2015 peer group in its 2017 proxy report.
For more information about the peer group submission process, companies can visit this ISS website: