French Market Engagement Disclosure

ISS STOXX provides French corporate issuers with an opportunity to review the factual accuracy of the data included in ISS STOXX’ pending proxy analyses. ISS STOXX believes that this review process helps improving the accuracy and quality of its analyses, an outcome that is in the best interests of both the institutional investors for whom the analyses are prepared, as well as for the issuers that are the subject of these reports.

This review process is open to those issuers who elect in advance of proxy season to participate.  By electing to participate in ISS STOXX’ draft review process, issuers agree to follow the process described below.

Election Process

Further to the terms of the AMF Recommendation, in addition to foregoing provisions of this policy, the provision of a draft proxy advisory report to issuers listed in France is subject to the following conditions:

• Each year, the issuer submits a written request for this facility at this e-mail address with “ISS STOXX Draft request” as subject;
• Such request is received by ISS STOXX preferably before the 15th of February and no later than 35 days prior to the date of the general meeting;
• Materials relating to the general meeting should be available at the latest 35 days before the general meeting. ISS STOXX France research team thanks companies in advance for notifying ISS STOXX upon publication of shareholder meeting materials.

Scope of Review

The purpose of providing a company with a draft report of its analysis is to allow the company to check the information prior to publication, thus allowing ISS STOXX to provide more accurate reports to its clients. It is not intended to be used as an opportunity for the company to lobby for a voting recommendation.

The point of view of issuers will be reflected in proxy advisory reports when the information is useful in helping our institutional clients make a more informed voting decision. In those instances, ISS STOXX may consider including quotes received in English from issuers.

No draft will be sent if the resolutions submitted to the general meeting concern merger and acquisitions, proxy fights or either resolution analyzed by ISS STOXX as contentious.

Timing

Subject to these conditions being met, ISS STOXX will use good faith efforts to provide the draft proxy advisory report to the issuer by electronic means 24 hours prior to publication to our clients for fact checking purposes. Such disclosure remains subject to our overriding obligation to deliver proxy advisory report to our clients prior to voting cut-offs and in accordance with contractual service level commitments. No comments received after this period will be taken into account in the final report sent to our clients; this being said, ISS STOXX will decide about the opportunity to issue a complementary report.

Dissemination of Proxy Analyses

Proxy advisory reports are copyrighted works which are the valuable intellectual property of ISS STOXX. Any prior disclosure of research reports to issuers, whether in France or elsewhere, is made on the condition of strict confidentiality and under no circumstances is an issuer to publish or otherwise disseminate all or part of the report.  ISS STOXX reserves the right to withhold disclosure in future years to an issuer which fails to observe this obligation of confidentiality, notwithstanding that the conditions for disclosure prescribed by the AMF Recommendation may have been met.

Contact Information Form

Please complete the form below to provide contact information for inclusion in the draft review process. Items marked with a star* are required. This information will be used solely for the purpose of distributing draft reports as outlined in the process above and will not be shared with any third parties or ISS STOXX affiliates.