Glass Lewis recently announced the opening of its 2025 Policy Survey. The survey seeks input on several key governance topics including board diversity, executive compensation, ESG considerations, shareholder rights, and emerging issues such as AI standards and changes in engagement practices as a result of recent updates to the SEC’s Compliance and Disclosure Interpretations (CDIs) on Regulation 13D-G. The survey questions often signal future changes to Glass Lewis’s voting policy guidelines.
The survey solicits views on, among other things:
- Board oversight and performance: Board diversity, director performance, and, driven by recently adopted state laws, adoption of ownership thresholds for submission of shareholder proposals or filing of derivative actions without shareholder approval
- Compensation: Non-executive directors’ fees, executive security costs, “make-whole” equity awards, ad-hoc adjustments to severance benefits, time-based incentive awards, the impact of tariffs on executive pay outcomes, and the importance of certain executive pay disclosures in light of the possibility of reduced disclosures from the SEC
- ESG: Response to “the growing anti-ESG sentiment in the U.S.,” company-wide diversity disclosures, and considerations relating to biodiversity and say on climate proposals
- Shareholder rights: Approach to reincorporation proposals considering developments over the past year, multi-class share structures, and virtual-only shareholder meetings
- General: AI benchmarks and standards, voting decisions based on financial factors versus corporate governance best practices, and, for investors, whether, they have changed or are considering making changes to their voting or engagement policies and practices as a result of the recent updates to the CDIs on Regulation 13D-G
The complete set of survey questions can be found here. While aimed primarily at investors, public companies, their advisors, and other stakeholders may also participate. The deadline to complete the survey is Monday, September 15, 2025, at 5:00 p.m. PT/8:00 p.m. ET.
