• 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 opinions on Glass Lewis’ research and recommendations. Each RFS is included with Glass Lewis’ research and made available to the voting decision-makers at every Glass Lewis investor client.
• RFS participants submit their RFS directly to Glass Lewis’ research team via our online submission platform. Once reviewed for alignment with guidelines stipulated below, the RFS is appended to the relevant Proxy Paper research report. The updated Proxy Paper with corresponding RFS is subsequently republished and distributed to all Glass Lewis clients through its research and voting platforms.
• Clients that previously downloaded the Proxy Paper research report are notified immediately by email when an RFS is available and can quickly access the RFS directly from the front page of the report.
• Once a Proxy Paper research report includes the RFS, that is the only version of the report available from Glass Lewis and prior versions are removed from distribution.

• No. All potential factual errors and omissions identified in a Proxy Paper 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, but please note that the IDR is not available in all markets and a list of participating markets can be found at the link above.

• No, there is no cost to meet with Glass Lewis’ research team. Requesting a meeting is, however, subject to analysts’ availability and only permitted during the times outlined in Glass Lewis’ Issuer Relations Policy & Procedures. To learn more about interacting with Glass Lewis, please visit the Issuer Relations page of our website here.

To be eligible to submit an RFS, all criteria below must be satisfied.

• Be a public company, shareholder proponent, dissident shareholder or party to an M&A transaction clearly identified in or covered by Glass Lewis’ research for the specific meeting.
• Have disclosed all relevant documents at least 21 days prior to the specific meeting.
• Have purchased the specific Proxy Paper research report directly from Glass Lewis as a company, shareholder proponent, dissident shareholder, or party to an M&A transaction, and not as an institutional investor or intermediary through a research-only or Viewpoint subscription. Proxy Paper research reports can be purchased here.
• For each specific shareholder proposal discussed in an RFS, the name of the proponent should be clearly identified from publicly available information.
• Submit the RFS no later than 14 days before the related shareholder meeting. Provided, however, that RFS submissions for meetings involving a proxy contest, an M&A transaction, or a dissident shareholder may be extended to no later than 7 days before the related shareholder meeting, at Glass Lewis’ discretion.
• Accept the terms and conditions of the RFS.

• The RFS provides you with the opportunity to speak directly to company shareholders and should be addressed directly to these shareholders (e.g., Dear Shareholders, Dear Owners, Fellow Shareholders). Please do not address the RFS to Glass Lewis or its research analysts.

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.
• The RFS does not contain any false or misleading factual statements.
• The RFS is intended to be a channel for companies and shareholder proponents to express their views on any differences of opinion with Glass Lewis, allowing Glass Lewis clients to conveniently compare the opinions of company management or shareholder proponents directly to those of Glass Lewis. As such, Glass Lewis understands that an RFS can, and often will, disagree with the analysis or recommendations in Glass Lewis’ research report. At the same time, Glass Lewis expects RFS participants to exercise professionalism and civility in their responses, to not disparage Glass Lewis or its affiliates or agents, to not include any unnecessary personal names or other personal data, and to refrain from comments that are not relevant to the voting issue(s).
• The RFS 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.

If an RFS submission contains a factual error or otherwise does not comply with these guidelines, Glass Lewis may provide the RFS participant the opportunity to submit a revised RFS that complies with the guidelines, provided there is sufficient time for publication before the relevant meeting’s vote cut-off date.  Glass Lewis reserves the right to decline to distribute an RFS or to issue its own corrective or clarifying statement along with an RFS in exceptional circumstances.

RFS submissions must be made no later than 14 days before the related shareholder 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.

RFS submissions for meetings involving a proxy contest, an M&A transaction, or a dissident shareholder may be extended to no later than 7 days before the related shareholder meeting, at Glass Lewis’ discretion.

• The RFS must be submitted on company letterhead and in PDF format.
• The use of graphics, charts, bullet points, specific fonts and hyperlinks is at the discretion of each participant.
• Submissions should be addressed to “Shareholders” or “Fellow Shareholders”, not to Glass Lewis.

All statements must be signed by an authorized signatory (electronic signature is acceptable).

• The RFS must be submitted on company letterhead and in PDF format.
• The use of graphics, charts, bullet points, specific fonts and hyperlinks is at the discretion of each participant.
• Submissions should be addressed to “Shareholders” or “Fellow Shareholders”, not to Glass Lewis.
• All statements must be signed by an authorized signatory (electronic signature is acceptable).

• No. The purpose of the RFS is to allow participants to directly express their views and any differences of opinion they have with Glass Lewis’ research and recommendations.
• The RFS is not intended to be a forum to evaluate or critique other firms, data providers or proxy advisors.
• Participants must refrain from, directly or indirectly, commenting on the views, analysis or vote recommendations of other proxy advisors, and from providing a comparative analysis between the research published by Glass Lewis and the research published by another proxy advisor.
• If there is a concern with the accuracy of any third-party data contained in a Proxy Paper report, those concerns should be addressed directly with the third-party data provider.

• In accordance with the requirements outline above, when purchasing a Proxy Paper research report as a company, shareholder proponent, dissident shareholder, or party to an M&A transaction, including subscriptions to the Glass Lewis Governance Hub platform, the cost of the report includes the RFS. Eligible shareholders with access to Glass Lewis’ research through a research-only or Viewpoint subscription must pay an additional fee to submit an RFS.
• 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 the statement.
• As noted above, Glass Lewis reserves the right to not publish an RFS or to issue its own corrective or clarifying statement in exceptional circumstances, although it will typically only do so after allowing the RFS participant an opportunity to submit a revised statement that complies with the RFS program guidelines.

• RFS participants are permitted to submit one RFS per shareholder meeting.
• If additional public filings result in a material revision to the Proxy Paper 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 must be submitted within 2 business days following the publication of the revised Glass Lewis research.

• Once a valid error or omission is reported, Glass Lewis will update the relevant Proxy Paper research report and republish it to clients with a note describing the changes.
• To be clear, Glass Lewis does not charge any fees for resolving factual issues. The purpose of the RFS is to address differences of opinion, not to charge for resolving factual errors or omissions.
• Further, through Glass Lewis’ IDR program, companies can check the data used to formulate Glass Lewis’ research, at no cost, prior to the applicable Proxy Paper research reports being published to Glass Lewis’ clients.
• If possible, RFS participants are encouraged to notify Glass Lewis of any material factual errors or omissionsas soon as possible, and no later than 2 business days prior to submission of an RFS to allow adequate time for correction and notification of Glass Lewis’ clients.

• No, 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.