A few of our members have informed us that the Glass Lewis window for peer group submissions is open – through August 14th – for companies with annual meetings between October 2026 and February 2027. Glass Lewis shares the info by email to the designated company contact, rather than making a public announcement like ISS. In order to receive these emails about peer group submission windows, you need to opt in.

As I’ve shared in years past, not every company needs to submit something during this window. You really only do it if your peer group has changed since your last proxy statement and you want to make sure the proxy advisor considers that. Glass Lewis lists these reasons for why you may wish to update your peer group:

1. You recently disclosed an updated peer group on your website, Form 8-K, or elsewhere in the public domain, but it’s not in your most recent Form DEF 14A or Management Information Circular.

2. Your most recent proxy statement includes two peer groups (e.g., one for fiscal 2025 and another for fiscal 2026). Confirm your preferred peer group by submitting it.

3. You publicly disclosed your fiscal 2026 peer group with changes for fiscal 2027, but without listing the full fiscal 2026 group. Submit an update to confirm the fiscal 2026 peer group.

This excerpt from the Glass Lewis “peer group” page explains how the information is used:

Glass Lewis has Glass Lewis has a rigorous, state-of-the-art peer methodology that informs our Pay-for-Performance Model, and our Say on Pay recommendations. Beginning with a company’s self-disclosed peers, Glass Lewis then includes investor views on both industry-based and country-based peers, in addition to the company’s peers-of-peers. This approach ensures additional screens based on corporate revenue, market capitalization, and assets; weightings also consider the source and frequency of confirmation, and peer rankings are based on a strength-of-connection approach that considers all potential peers, not just those resulting from the network effects of corporate disclosures.

To submit an updated peer group, you’ll need to carefully follow the instructions on this page. Note that the Peer Group Submission document was updated this year – so don’t use the old version. You also need to make sure to use the Glass Lewis portal to submit your information, as email submissions won’t be accepted.

We will get the latest scoop from ISS & Glass Lewis at our upcoming “Proxy Disclosure & 23rd Annual Executive Compensation Conferences” – happening October 12-13 in Orlando and virtually. Register now to ensure you get the information you need for your 2027 proxy season. You can register online or by contacting us at info@CCRcorp.com or 1-800-737-1271.

– Liz Dunshee

I don’t want to get too far ahead of ourselves with speculating about potential changes to the SEC’s executive compensation disclosure rules. But I will note that despite overall exuberance on the company side about the prospect of less onerous disclosure, there is also some acknowledgement that companies could lose benchmarking insight that is currently available through proxy disclosures. So, get it while you can! Mark Borges continues to share noteworthy proxy disclosure examples on his “Borges’ Proxy Disclosure Blog.” Here are a few of Mark’s recent updates addressing various aspects of compensation disclosures:

– Powerfleet’s Stockholder Engagement Disclosure

– Casey’s General Stores Executive Pay Summary

– ePlus’s Clawback Disclosure

– Monro’s Realized Pay Comparison Disclosure

– Universal Corp.’s Compensation Discussion and Analysis

– J.M. Smucker’s Defined Benefit Plan Disclosure

– Allegro MicroSystems’ Compensation Discussion and Analysis

– Brown-Forman’s Special Recognition Award Disclosure

Mark doesn’t simply flag the disclosure – although even that is helpful! He also adds context and commentary from his years of experience. Members of this site can visit the blog – and can sign up to get that blog pushed out to them via email whenever there is a new entry. All you need to do is click the link on the left side of the blog and enter your email address.

If you aren’t yet a member with access to the Borges’ Proxy Disclosure Blog and all of the other resources on this site – such as our checklists, resource libraries, and the essential Lynn & Borges’s “Executive Compensation Disclosure Treatise” – email info@ccrcorp.com, call 1.800.737.1271, or sign up online.

– Liz Dunshee

Here’s an interesting note from the latest Semler Brossy newsletter:

Secondary peer groups — ”Supplemental peers,” “Reference peers,” etc. — are more prevalent now because they can contextualize programs and practices in the broader talent market. For example, the pay programs, performance leverage, and equity usage at industry-dominant companies are important information, even if the value of CEO pay is not a valid comparison.

Questions for the board:

1. Does the primary peer group sufficiently reflect sources and destinations of executive talent?

2. Is information from a broader group useful?

Members can visit our “Peer Groups” Practice Area for more info on creating and using peer groups.

– Liz Dunshee