Courtesy of Proxy Analytics, State Street Investment Management (SSIM) posted its updated Global Proxy Voting and Engagement Policy (redline here) and related resources for the 2026 proxy season.
The Summary of Material Changes notes the inclusion of US-specific engagement guidelines, the systematic embedding of financial performance—based on a relative total shareholder return (TSR) metric—into certain voting policies, and the adoption of a streamlined framework for consideration of shareholder proposals.
The US-specific guidelines, set forth in Appendix A of the Policy, describe how SSIM conducts engagements with US public companies. Among other things, presumably responsive to the SEC’s 2025 guidance on shareholder engagement (we reported on here and here), SSIM states that it does not seek to influence or change control of portfolio companies, will not dictate or pressure companies to adopt specific policies or business decisions, and will not discuss certain topics—such as specific emissions targets or capital allocation—during engagements. Presumably responsive to the US-specific political and regulatory environment, the guidelines also state that SSIM will not apply or discuss specific gender, racial, or ethnic diversity targets or thresholds in connection with US portfolio companies.
SSIM’s updated framework for evaluating shareholder proposals states:
We believe that company boards do right by investors and are responsible for overseeing strategy and company management. To that end, we do not support shareholder proposals that are on a topic that the company has not determined to be material to its business or that appear to impose changes to business strategy or operations, such as increasing or decreasing investment in certain products or businesses or phasing out a product or business line.
When assessing shareholder proposals, the Policy provides that SSIM considers whether the adoption of the resolution would promote long-term shareholder value in the context of our core governance principles:
- Effective board oversight
- Quality disclosure
- Shareholder protection