ISS REVIEW PROCESS
FOR INDIA ISSUERS
To facilitate compliance with procedural guidelines promulgated by the Securities and Exchange Board of India applicable to proxy advisory firms, ISS India provides corporate issuers based in India with a mechanism to review and, if they wish, provide comments to ISS India regarding ISS’ final, published proxy research report and voting recommendations (“report”) covering an issuer. This review and comment process is open to all corporate issuers based in India that are the subject of an ISS India proxy research report.
Comments received under this process will be reproduced in an addendum to the original report which will be made available to those ISS clients that received the original report. By electing to participate in this process, all eligible issuers agree to the following:
- Issuers intending to provide comments on a report must first be registered to receive a copy of their report. An overview of the registration process to receive the final report can be found here.
- All comments must be emailed within 24 hours of the issuer being notified of the publication of the relevant report to the ISS email address (or addresses) provided in the report.
- Comments must clearly identify the applicable section(s) of the comment document which the issuer intends to be included in the addendum to the report. An addendum will not be released if this requirement is not met.
- Comments must not include any unpublished price-sensitive or other material non-public information.
- ISS India will not be responsible or liable for the accuracy, legality, and content of the comments provided. By providing comments to ISS India, the issuer affirms ISS India’s right to publish those comments to its clients.
- Other than reproducing the comments received from the issuer in the addendum, ISS India reserves the right, but has no requirement, to publish its own response to any commentary documents provided by an issuer.
- Under no circumstances may an issuer publish or otherwise disseminate all or part of an ISS report. ISS India reserves the right to withdraw the comment mechanism described above in future years for issuers that fail to observe this obligation of confidentiality/intellectual property protection.
