Due Diligence Resources

This summary helps map existing Glass Lewis policies and procedures to the SEC Guidance Regarding Proxy Voting Responsibilities of Investment Advisers and the use of Proxy Advisory firms.

Glass Lewis takes all appropriate steps to prevent, identify, and manage circumstances that may give rise to potential, perceived or actual conflicts of interest. Glass Lewis’ Policies and Procedures for Managing and Disclosing Conflicts of Interest outline the mechanisms in place to identify, mitigate, and disclose potential conflicts.

Glass Lewis’ Code of Ethics sets forth Glass Lewis’ commitment to ensure all individuals acting on its behalf fully comply with all laws, regulations, standards of care, ethical business practices, as well as the basic standards expected in the workplace. It also contains policies on personal securities trading, external engagement with issuers and interested parties, and the disclosure of personal interests and/or control positions involving a listed company.

Glass Lewis prides itself on its reputation for conducting business activities in the highest ethical and professional manner and does not tolerate modern slavery in its business or supply chains, taking effective steps to meet this commitment.

Glass Lewis is committed to the highest standards of honesty, propriety and integrity in all of its activities. Fraud of any kind is strictly forbidden.

A zero-tolerance approach is applied to bribery and corruption at every level of Glass Lewis’ business. Glass Lewis complies with all anti-corruption laws where it does business, including but not limited to the U.S. Foreign Corrupt Practices Act (the “FCPA”) and the UK Bribery Act 2010 (the “UK Bribery Act”). 

Glass Lewis will not knowingly engage in financial transactions that involve proceeds from an unlawful activity or that support terrorist activities, nor will Glass Lewis engage in financial transactions with individuals, entities and restricted countries designated by The U.S. Department of the Treasury Office of Foreign Assets Control (OFAC) or similar sanctions regulations in other countries where Glass Lewis does business.

Glass Lewis believes it is in the best interest of our organization, employees, clients and society in general, to move along a path toward sustainability by promoting and practicing social, economic and environmental responsibility. Glass Lewis’ path to sustainability is two-fold: we promote sustainability both in the marketplace through our customer solutions and in our own operations. This Sustainability Policy outlines the material areas, objectives, and practices that make up our two-fold path to sustainability. 

Glass Lewis and its UK-based subsidiary, GL & M UK Ltd., are registered with the Financial Conduct Authority as proxy advisors, as required by The Proxy Advisors (Shareholders’ Rights) Regulations 2019.