Beginning on Wednesday, November 20, 2013, Institutional Shareholder Services (ISS) is soliciting changes from companies to their self-selected peer groups used in compensation determinations.

ISS constructs company peer groups for purposes of conducting its pay-for-performance analysis each proxy season. ISS generally selects 14 to 24 peers based on:

For companies that have changed their peer groups since their 2013 proxy statement filing and used this revised peer group for compensation decisions in 2013, ISS is providing an opportunity to submit updated peer group information to ISS through its feedback form available on its website. ISS will consider the information submitted when constructing the peer group to be used in its analysis. Companies should be mindful that ISS is requesting additional confirmation of the revised peer group on company letterhead in a separate e-mail to [email protected].

Companies that wish to provide peer group information used for benchmarking CEO compensation in 2013 must complete the feedback form with the necessary attachments and submit it to ISS by 5:00 p.m. EST on December 9, 2013.

For more information on dealing with ISS and other proxy advisory firms, including details of ISS's pay-for-performance evaluation, see Practice Note, Developing Relationships with Proxy Advisory Firms.