Glass Lewis Will Include Company Feedback In Proxy Reports

On April 2, 2020, Glass Lewis announced a significant change to the manner in which it conducts its business. It will now include company feedback in its proxy reports without any rebuttals or other statements made about such company statement. The full text of the Glass Lewis announcement is at https://www.glasslewis.com/report-feedback-statement-included-with-research/

Companies will now have 7 days after Glass Lewis publishes its report to provide feedback. Feedback can be provide using Glass Lewis’ Report Feedback Statement webpage (https://www.glasslewis.com/report-feedback-statement/). Glass Lewis will then republish its proxy report and include the statement from the company.

Given that Glass Lewis has changed its peer group methodology for the 2020 proxy season, we may see more companies provide feedback this year as the change in peer groups may be dramatic and could have implications for the letter grades Glass Lewis assigns companies under its pay-for-performance analysis as part of its Say-on-Pay vote recommendation process.

I applaud Glass Lewis for taking this step and hope their subscribers will take company feedback provided seriously. At the same time, companies should provide feedback only where warranted and where specific issues have been identified. If both do so, it should help ensure that company feedback becomes a meaningful part of the Glass Lewis proxy reports.