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September 3, 2025

More on Glass Lewis’s Upcoming Changes to Pay-for-Performance Model

As Meredith shared in early July, Glass Lewis is planning to change its quantitative pay-for-performance model for the 2026 proxy season. We probably won’t know all the details until mid-October (at least), but this FW Cook blog describes what we know so far about the new multi-test scorecard. Here are a few key points:

– Replaces the current letter grading system (i.e., A to F) with a numerical scorecard

– Extends the pay-for-performance alignment measurement period from 3 years to 5 years

– Expands the relative pay and performance comparisons beyond the GL peer group to include broader general industry and market capitalization peers

– Utilizes multiple definitions of pay with the introduction of CAP to the model

The blog provides detailed charts about Glass Lewis’s new scorecard approach. According to FW Cook’s summary, there will be five relative tests and one qualitative test (i.e., six total) – and the charts summarize the various tests and factors.

Under this model, you want to get a high score. Glass Lewis will use the relative tests to calculate a numerical overall P4P alignment score that ranges from 0 to 100, and will apply the qualitative test as a negative modifier – i.e., it can only reduce the overall P4P alignment score. The overall score translates to a level of P4P misalignment concern ranging from negligible (81 – 100) to severe (0 – 20).

Liz Dunshee

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