Guidance for Proxy Advisory Firms

IGOPP has issued in 2013 a policy position on the role of proxy advisors titled The Troubling Case of Proxy Advisors: Some policy recommendations. This submission draws largely from that policy paper and, hence, it is attached as an appendix.

The proposals of the CSA to raise somewhat the level of disclosure requested from proxy advisors is commendable but clearly not sufficient. Normative measures are required to ensure appropriate supervision of the activities of proxy advisors, given their significant influence on corporate governance and their role in the processes of acquisitions and proxy battles.

Numerous issues are identified in the Proposed National Policy 25-201. We intend to respond by addressing the specific questions contained in the CSA Notice and Request for Comment.