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Going Beyond: Proxy Alignment

Top FTSE 100 Institutional Investors Alignment with ISS & Glass Lewis

Top FTSE 100 Institutional Investors Alignment with ISS & Glass Lewis

ByOliver Taylor

Summary:
Top FTSE 100 Institutional Investors Proxy Alignment

Deconstructing the "Blind Following" Narrative

While a strong alignment rate with ISS “FOR” recommendations may suggest that FTSE 100 investors simply adopt proxy advisor guidance, the underlying data presents a far more differentiated picture when examining “AGAINST” recommendations. Only one of the 15 investors assessed shows high alignment with ISS on negative votes. Eight exhibit moderate-to-high correlation (approximately 34%–75%), while the remaining seven demonstrate significant independence, with alignment dropping to as low as 19%. This divergence on contentious items indicates that FTSE 100 investors are exercising their own judgement rather than “outsourcing” decision-making.

The "Decision-Maker" Myth

The data makes clear that while proxy advisors help establish a reference point for voting expectations, they do not determine final outcomes. The substantial variation in alignment across “AGAINST” recommendations shows that investors ultimately rely on their own governance assessments rather than external instruction. Taken together with the broader factors outlined in ‘Interpreting Congruence & Possible Reasons for Voting Alignment’, the commonly held view of proxy advisors as the hidden decision-makers at FTSE 100 AGMs appears increasingly difficult to support.

From Ex-Post Observation to Ex-Ante Strategy

While ISS and Glass Lewis recommendations remain useful statistical indicators, their assessments are inherently retrospective and reactive. Securing favourable AGM outcomes requires a shift from monitoring proxy advisor outputs to proactively understanding investor-specific policies well before the publication of any reports. By aligning agenda items, governance practices, and strategic communications with the expectations of key shareholders, companies can mitigate risks long before AGM season. Ultimately, success is shaped not by last-minute adjustments but by a sustained, forward-looking engagement strategy tailored to the nuances of each investor’s guidelines.

Congruence & Divergence with ISS & Glass Lewis

Voting Congruence & Divergence with ISS & Glass Lewis

To better understand the congruences & divergences between voting recommendations from proxy advisors and observed investor voting behaviour, we analysed four categories for each of the both proxy advisors:

  1. ISS recommended FOR, Investor voted FOR
  2. ISS recommended FOR, Investor voted AGAINST
  3. ISS recommended AGAINST, Investor voted AGAINST
  4. ISS recommended AGAINST, Investor voted FOR
  5. Glass Lewis recommended FOR, Investor voted FOR
  6. Glass Lewis recommended FOR, Investor voted AGAINST
  7. Glass Lewis recommended AGAINST, Investor voted AGAINST
  8. Glass Lewis recommended AGAINST, Investor voted FOR
1

ISS FOR Voting FOR-Alignment

  • When ISS recommended FOR, 12 institutional investors voted FOR in 99% or more of these cases.
  • Three institutional investors have an alignment between 97.2% and 91.7%.
2

ISS AGAINST Voting AGAINST-Alignment

  • Two institutional investors have an alignment between 96% and 88.9%.
  • Three institutional investors have an alignment between 73.7% and 50%.
  • The remaining ten institutional investors have alignments between 44% and 19.1%.
3

Glass Lewis FOR Voting FOR-Alignment

  • When Glass Lewis recommended FOR, 10 institutional investors voted FOR in 99% or more of these cases.
  • The remaining five institutional investors have an alignment between 98.7% and 91.4%.
4

Glass Lewis AGAINST Voting AGAINST-Alignment

  • Only one of the 15 institutional investors have an alignment over 70% when Glass Lewis recommended AGAINST.
  • Two institutional investors have an alignment between 50% and 70%.
  • The remaining 12 investors have an alignment between 44.4% and 16.7%.
InvestorVoted ItemsProxy AdvisoryISS + Voting +ISS + Voting -ISS - Voting -ISS - Voting +GL + Voting +GL + Voting -GL - Voting -GL - Voting +
Amundi1798ISS & Glass Lewis91.7%8.3%44%56%91.4%8.6%33.3%66.6%
Black Rock 1827ISS & Glass Lewis99.2%0.8%36%64%99.1%0.9%38.9%61.1%
Capital Group 917ISS97.2%2.8%20%60%97.1%2.9%20%80%
Columbia Threadneedle 1852ISS99.9%0.1%23.8%76.2%99.8%0.2%17.7%82.3%
Dimensional Fund Advisors 1792ISS & Glass Lewis99.3%0.7%96%4%98.7%1.3%72.2%27.8%
Fidelity FMR 1430ISS & Glass Lewis99.1%0.9%22.7%77.3%99.2%0.8%37.5%62.5%
Geode Capital 1562ISS99.9%0.1%24%76%99.8%0.2%16.7%83.3%
Invesco Asset Management 1833ISS & Glass Lewis99.8%0.2%19.1%80.9%99.7%0.3%18.8%81.2%
JP Morgan Asset Management1852ISS & Glass Lewis99.9%0.1%24%76%99.8%0.2%16.7%83.3%
MFS Investment Management 1215ISS & Glass Lewis99.4%0.6%50%50%99%1%50%50%
Norges Bank 1682ISS99.8%0.2%25%75%99.6%0.4%16.7%83.3%
Northern Trust 1588ISS99.1%0.9%88.9%11.1%98.5%1.5%53.3%46.7%
State Street Investment 1852ISS95.6%4.4%52%48%95.4%4.6%44.4%55.6%
T. Rowe Price 1483ISS & Glass Lewis99.7%0.3%73.7%26.3%99.1%0.9%40%60%
Vanguard 1852ISS & Glass Lewis99.8%0.2%24%76%99.8%0.2%27.8%72.2%

“+” indicates a positive recommendation or vote (FOR).
“-” indicates a negative recommendation or vote (AGAINST).

Interpreting Congruence & Possible Reasons for Voting Alignment

Interpreting Congruence: Why High Alignment Is Not Proof of Causation

  • In a paper by Robert Matthews in 2000 titled“Storks Deliver Babies (p=0.008)”, the Stork-Baby Correlation was examined.
  • The examined data showed that a highly statistically significant correlation exists between stork populations & human birth rates across Europe.
  • As the author notes, this “shows that a highly statistically significant correlation exists between stork populations and human birth rates across Europe. While storks may not deliver babies, unthinking interpretation of correlation and p-values can certainly deliver unreliable conclusions.”

Possible Reasons for Voting Alignment with Proxy Advisory

Shared Best Practices: Both investors and proxy advisors frequently operate from the same global governance ‘playbooks.’ Frameworks established by organizations such as the ICGN, UN PRI, and the OECD, alongside national Corporate Governance Codes (such as the DCGK in Germany), create a standardized baseline for high-quality governance. Consequently, high alignment might reflect a shared adherence.

Routine Consensus: A certain portion of AGM agendas consist of “routine” or non-controversial items, such as dividend payments or the appointment of auditors. In these cases, there is a natural market-wide overlap in voting, which mathematically inflates alignment percentages.

Feedback Loops: ISS and Glass Lewis conduct comprehensive annual policy surveys and regular client consultations to ensure their benchmarks remain aligned. By incorporating this direct input into the guidelines, proxy advisors adopt a form of consensus views.

Non-Glass Lewis Clients: The high level of alignment observed among ISS-exclusive clients with Glass Lewis recommendations might indicate that proxy advisors are not necessarily standard-setters, but act as mirrors of an existing basic market consensus.

Methodology

  • Our study examines 15 of the largest international institutional investors, selected based on average investment size and strategic shareholder structures.
  • For the 2025 FTSE 100 Annual General Meeting (AGM) season, we analysed voting recommendations from leading proxy advisors ISS and Glass Lewis.
  • To ensure a consistent baseline for voting guidelines and investor expectations, we excluded companies without full proxy coverage -typically due to insufficient free floats.
  • Consequently, this report focuses on 85 FTSE 100 companies, cross-referencing their proxy recommendations against the actual voting records of our 15 selected investors.

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