TheCorporateCounsel.net

March 13, 2019

Pay Ratio – Year 2: Sample “Median Employee” Disclosures

Here’s something that Liz blogged about on CompensationStandards.com: One of the most frequent questions we get about this year’s pay ratio disclosure is, “How much detail is necessary if you’re not rerunning the ‘median employee’ calculation?” In other words, you’re either using the same median employee – or one of the alternates – that you identified last year. A timely blog from Stinson Leonard Street’s Steve Quinlivan provides examples from four recent filers.

You’ll see that the companies didn’t get too elaborate. All of them basically parrot Instruction 2 to Item 402(u) – i.e. they say they used the same median employee (or an alternate) since there was no change in the employee population or employee compensation arrangements that they believed would significantly change the pay ratio disclosure. And since Steve notes in this blog that he’s found zero Corp Fin comments so far on pay ratio disclosures, that’s probably just fine.

Tomorrow’s Webcast: “The Top Compensation Consultants Speak”

Tune in tomorrow for the CompensationStandards.com webcast — “The Top Compensation Consultants Speak” — to hear Mike Kesner of Deloitte Consulting, Blair Jones of Semler Brossy and Ira Kay of Pay Governance discuss these topics:

– Second year of pay ratio
– Evolution of clawbacks
– Adjustments to incentive plan actual performance or goals & goal-setting plans
– Incorporating E&S metrics into plans
– How to handle pay equity & gender/ethnicity pay gaps
– The changing role of the compensation committee

“Valley of the Boom”: Loved It

Have you seen the 6-part miniseries from National Geographic called “The Valley of the Boom“? Very well done (I don’t know why the ratings on Metacritic aren’t higher). Brought back lots of memories from the mid-90s when I earned my stripes as the “Internet guy” in Corp Fin.

It’s the most entertaining thing I’ve seen on the Internet boom. A mix of a documentary and a reenactment of how things played out at Netscape, TheGlobe.com (which was Facebook before Facebook) and a scam artist who actually had high quality video streaming before anyone else. The documentary part has remarks from those who were at Netscape & Microsoft (remember the “browser wars”?), as well as commentary from celebrities like Mark Cuban and Arianna Huffington…

Broc Romanek