July 22, 2026
ISS’s Annual Policy Survey: Compensation Topics
Yesterday, ISS announced the launch of its Annual Global Benchmark Policy Survey. Meredith shared the high points over on TheCorporateCounsel.net – but it’s worth calling out the survey’s compensation-related questions here too:
– Whether discretionary bonus programs warrant different sector-specific treatment for financial services companies rather than generally being treated as a concern in the qualitative pay-for-performance evaluation since financial services companies indicate that formulaic bonus structures are incompatible with applicable regulatory and risk management requirements
– Whether enhanced disclosure around the use of discretion by financial services companies would mitigate concerns
– How to signal significant concerns regarding executive pay when no say-on-pay vote is on the ballot given that more companies may be exempt if the SEC’s “Filer Status” proposal is adopted (e.g., whether to vote against compensation committee members and which members) and what support level for compensation committee members should be considered a low vote that triggers ISS’s responsiveness policy (the 50% director election threshold or the 70% say-on-pay threshold)
– Whether and when the risk of competitive harm constitutes a compelling rationale for not disclosing forward-looking LTI performance targets
– Whether the rationale of potential competitive harm is less compelling for relative metric goals than for absolute metric goals
The survey is scheduled to close on August 14, 2026, at 5 p.m. ET. In addition to the survey, ISS will conduct a series of regional, topic-specific roundtable discussions.
– Liz Dunshee
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