ISS has issued its preliminary US post-season report, which is full of useful statistics about the 2011 proxy season for the data hound.  Broc notes some of the key highlights in TheCorporateCounsel.net blog.

The report also provides a possible hint on the question of what level of dissent for say-on-pay votes, beyond failed votes, could cause additional ISS scrutiny.  Based on the text in the report as noted below, it appears that companies that received below 70% approval may be targeted, though what “greater attention” means in this context is unclear:

“While investors will have different thresholds for which firms they will scrutinize more closely, it appears likely that issuers with greater than 30 percent opposition this year will receive greater attention in 2012.   According to ISS data, 168 companies, or about 6 percent of the total, received more than 30 percent dissent this proxy season.”


This communication, which we believe may be of interest to our clients and friends of the firm, is for general information only. It is not a full analysis of the matters presented and should not be relied upon as legal advice. This may be considered attorney advertising in some jurisdictions. Please refer to the firm's privacy notice for further details.