Yes, we review the vast majority of shareholder proposals on a case-by-case basis. While Wellington Management does not rely on any external parties for recommendations or vote determinations, we do subscribe to the research products supplied by various proxy advisors and research providers, including ISS and Glass Lewis.
Wellington's Proxy Voting Guidelines outline our approach to evaluating these resolutions, with shareholder proposals denoted with "SP" next to them. For example, our approach to shareholder proposals requesting the adoption of a clawback policy is as follows: We believe that companies should have the ability to recoup incentive compensation from members of management who received awards based on fraudulent activities or an accounting misstatement. Consequently, we may support shareholder proposals requesting that a company establish a clawback provision if the company’s existing policies do not cover these circumstances.