Report Feedback Statement (RFS)

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

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• 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.

No. Reporting potential errors and engaging with Glass Lewis research analysts are separate from the RFS.

• All potential factual errors and omissions identified in a Proxy Paper should be reported as soon as possible via our dedicated feedback form.
• Eligible companies can participate in our complimentary pre-publication Issuer Data Report program (IDR), to verify data used by Glass Lewis to formulate its analyses and recommendations.

Yes. 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, its affiliates or its 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).

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The RFS is the participant’s opportunity to make a statement of its views and Glass Lewis will not edit or alter the statement. However, all RFS participants must ensure the following prior to delivering their feedback statement to Glass Lewis:

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• 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”, meaning the information has been disseminated in a manner that makes it widely available to investors.
• The RFS does not contain any false or misleading factual statements.
• The RFS is signed by an executive or authorized signatory and includes contact information that enables investors to follow up directly with the organization.

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If an RFS submission contains factual errors or does not comply with the above guidelines, Glass Lewis may provide the participant an 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.  
In exceptional circumstances, Glass Lewis reserves the right to decline to distribute an RFS or to issue its own corrective or clarifying statement along with an RFS 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.

• 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.

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• 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.

RFS participants are permitted to submit one RFS per shareholder meeting.

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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 Glass Lewis’ revised research.

Yes, Glass Lewis always seeks to offer eligible companies, shareholder proponents, dissident shareholders, or parties to an M&A transaction the opportunity to submit the RFS and, in doing so, may inform the other side of another party’s decision to submit an RFS.

RFS submissions should be made more than 14 days before the related shareholder meeting to ensure investors have sufficient time to consider the details ahead of voting deadlines. 


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RFS submissions for meetings related to special situations, such as a proxy contest or an M&A transaction, should be made more than 7 days before the related shareholder meeting. 


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Any extension to these deadlines is at Glass Lewis’ discretion and in consideration of vote cut-off dates.

No, the RFS process occurs after the publication of Glass Lewis’ research and recommendations and before the voting deadline so client investors can consider the statement in time to make or change their voting decisions.

A Governance Hub subscription or individual purchase of a Proxy Paper entitles eligible parties to submit a Feedback Statement. The RFS is not included with research-only or Viewpoint subscriptions, but is available to such subscribers, when eligible, for an additional fee.

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Glass Lewis’ research reports can be purchased here.