ISS is still seeking comments on its 2012 draft proxy voting policies. A critical component of ISS' annual policy formulation process, this comment period allows institutional investors, corporate issuers, and governance market participants to provide feedback on ISS' policy updates while they are still in draft stage. The comment period runs through Oct. 31 and includes ISS' U.S. and international policies.

"ISS firmly believes that incorporating multiple views on corporate governance issues is critical for effective policy formulation," said Martha Carter, ISS' Head of Global Research. "The uniquely transparent and collaborative nature of our policy formulation process serves not only to inform our policies, but also helps to create a higher level of understanding and dialogue across the corporate governance community."

To ensure its voting policies reflect the perspectives of the corporate governance community and represent the collective voice of its institutional clients, ISS gathers broad input each year from institutional clients and market constituents through policy surveys, issue-specific roundtables, and this unique open comment period. During this year's policy survey, more than 300 respondents weighed in on issues that included executive compensation, board independence, engagement triggers, and social and environmental issues. The full results from the survey are posted on the ISS Policy Gateway.

The proposed policy changes include a more robust pay-for-performance policy for the U.S. and Canada with a longer-term focus on trends in total CEO compensation and shareholder return. The proposed policies also address the responsiveness of boards to significant shareholder opposition during say-on-pay votes and to investor preferences during say-on-pay frequency votes.

ISS also is seeking comment on draft policy changes on these topics:

• Proxy Access Proposals (U.S.)
• Election of Censors (France)
• Board Independence (Brazil)
• Equity Plans Related to Section 162(m) (U.S.)
• Equity-Based Compensation (France)
• Increase in Director Compensation Ceiling Proposals (Japan)
• Hydraulic Fracturing Proposals (U.S.)
• Political Contribution Proposals (U.S.)

ISS will release its final 2012 U.S. and international policy updates during the week of Nov. 14 and its Global Policy Summary and Concise Guidelines in December. To participate in ISS' comment period and learn more about its policy formulation process, please visit the ISS Policy Gateway. --Bimal Patel, ISS Governance Institute