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Results from: TheCorporateCounsel.net
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Davies Governance Insights 2015 Published: 2015-11-17 21:08:01... 73% 72% 82% 81% 74% 2015 2014 2013 2011 TSX 60 Completion Index SmallCap Index CLAWBACKS Clawback provisions require CEOs to either repay some or all of their bonuses or ...
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Copyright © 2022 Wilson Sonsini ... Published: 2022-12-15 16:07:08... Compensation Recoupment ("Clawback") Provisions Glass Lewis updated its guidance on ... listing standards to implement the new clawback policy rules, after which listed ...
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Plan Scorecard Frequently Asked Questions Published: 2025-04-02 10:48:58... practice, particularly for large cap, mature companies. › A clawback policy that includes equity grants - clawback policies are seen as potentially mitigating excessive ...
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Faster, Stronger, Better. Published: 2021-11-08 11:25:39... our programs that include a stringent clawback policy, rigorous stock ownership ... or pledging Company stock * Stringent clawback policy applicable to directors and ...
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01959-HC ERP74_v3.indd Published: 2008-12-01 20:36:36... Proposals that saw some action in 2008 included "say on pay," a ban on tax gross-ups, clawback provisions, and internal pay equity policies. Review governance policies. It may be ...
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ExecComp_Update_021609.qxp Published: 2009-02-17 15:59:44... Clawback of Bonuses for Deceptive Practices The Act contemplates the recovery of any ... this provision would apparently permit a clawback even where the affected employee had no ...
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http://www.simpsonthacher.com/newsletter/index.cfm?itemId=F9510 Published: 2009-02-20 12:05:13... Clawback on Bonuses Paid to "Top 25" based on Materially Inaccurate Financial Statements. ... that the employees subject to this clawback provision be responsible for the inaccuracy). ...
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W&C Standard Template Published: 2018-02-21 14:16:10... Expanded Clawback In addition to supporting shareholder proposals for clawbacks from any senior executive whose compensation was based on faulty financial reporting or deceptive ...
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Microsoft Word - 9179_WeilBriefing_CG_2009-12-14.doc Published: 2009-12-15 11:28:21... such other period determined by the SEC. 18 Clawbacks of Unearned Performance-Based Pay. ... than the existing incentive compensation clawback provided by Section 304 of the Sarbanes- ...
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OFFICE OF THE NEW YORK CITY COMPTROLLER SCOTT M. STRINGER | 1 Published: 2020-12-02 18:22:33... The letter called on the board to enact a clawback policy to empower the board to recoup ... Opioid-Related Risks at Johnson and Johnson Executive Compensation Clawback Disclosure ...
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Deconstructing Proxy Statements - What Matters to Investors Published: 2015-02-17 15:30:34... pay 28 Board evaluation process 28 Clawbacks 24 Corporate social responsibility or ... profile 10 Board evaluation process 10 Clawbacks 7 Realized/realizable pay 5 Ratio of ...
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Inside back cover Published: 2015-12-18 11:09:34... in accordance with SEC rules (commonly known as "clawback of executive compensation"). ... Additionally, companies may wish to add a reference to establishing clawback policies to ...
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Empirical Research on ESG Factors and Engaged Ownership Published: 2021-12-03 10:25:34...0and%20Mullainathan_2001_Elites.pdf. 25. Clawback provisions enabling the recoupment of ... Chan, L., Chen, K. C. W., Chen, T. and Yu, Y. 2011. The Effects of Firm-Initiated Clawback ...
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7175502_1.DOC Published: 2009-01-16 12:25:15... Previously, RiskMetrics did not support shareholder proposals on "clawbacks" of incentive ... Both of these policy positions, as well as RiskMetrics' "best practices" for clawbacks, ...
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Blank Published: 2017-01-13 17:40:50... CFO Clawbacks In a significant legal development for the Division of Enforcement, a federal court of appeals recently affirmed the authority of the SEC to obtain clawbacks of ...
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2024-2025 YEAR-END TOOL KIT Published: 2025-02-21 11:07:04... Summary of Requirement Clawback check boxes: added by Listing Standards for Recovery of ... Summary of Requirement Clawback check boxes: added by Listing Standards for Recovery of ...
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Hunton & Williams Corporate and Securities Law Update: Executive... Published: 2010-07-20 19:55:31... Certain Enforcement Reforms Incentive Compensation Clawbacks Section 954 of Dodd-Frank ... The Dodd-Frank clawback requirement goes beyond the similar provision in the ...
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WSGR Alert Published: 2025-01-06 14:39:26... "robust" clawback policy in the "Executive Compensation Analysis" section of its company research reports for purposes of say-on-pay vote evaluations, a company's clawback policy ...
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Brian V. Breheny Published: 2014-11-12 17:57:14... conditions; whether the company has a clawback policy; and whether the company has ... tices" analysis. * For a company with no clawback or share holding period requirements, ...
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The Emergency Economic Stabilization Act of 2008 Published: 2008-10-06 11:40:37... that encourage unnecessary risk-taking, clawback of bonuses or incentive compensation ... Notably, the standards for clawbacks and golden parachute payments only apply to "senior ...
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What audit committees should prioritize in 2023 (pdf) Published: 2023-05-24 19:21:41... for the clawback of incentive-based compensation due to an accounting restatement. ... Companies that have clawback policies should review the terms and consider what changes ...
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GLASS LEWIS - POLICY UPDATES FOR 2023 PROXY UPDATE Published: 2023-02-15 15:49:36... to create new listing requirements for clawback policies in the event of a financial ... to raise concerns at companies with clawback policies that only meet the requirements ...
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Corporate Governance Developments and Proposals Published: 2009-07-28 13:24:55... Compensation Proposals (continued) Clawback on Unearned Performance-Based Pay * Require ... are currently subject to special clawback requirements under circumstances ...
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TheCorporateCounsel.net Published: 2024-05-02 08:05:59... would include a failure to adopt a compliant clawback policy within 60 days of October 2, 2023). If NYSE determines that a clawback delinquency has occurred, it will promptly ...
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Microsoft Word - 20110801 SEC Petition.doc Published: 2011-08-04 12:39:09... (18), executives' golden parachutes (7), clawback of incentive compensation (3), and ... (1), executives' golden parachutes (7), clawback of incentive compensation (1), and ...
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Microsoft Word - PGDOCS-#6328790-v2-EXPRESS_SCRIPTS_-_COMPLAINT... Published: 2014-01-07 11:39:00... "[t]here was no clawback policy to recoup unearned executive pay based on fraud or error." ... This statement is false. Express Scripts adopted a clawback policy in 2011, which became ...
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2017 PROXY SEASON PREVIEW By Shirley Westcott April 2017 Overview Published: 2017-04-03 12:18:00... major banks on notice to review their clawback policies, risk controls, and employee ... The 2016 Act additionally limited the scope of the clawback rule and amended the SOP ...
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Inside back cover Published: 2012-12-04 15:34:48... items: Implementation and Disclosure of Clawback and Hedging Policies The Act requires ... policy that provides for the recoupment (clawback) of incentive-based compensation in ...
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http://www.dlapiper.com/the-government-acts-on-multiple-fronts... Published: 2009-03-11 22:46:44... that meets certain terms and conditions; Clawback requirements for any bonuses, retention ... that are prohibited and/or subject to clawback requirements; Determining the limits on ...
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Section 1 Published: 2010-08-16 13:37:42... Executive Compensation and Clawback. Section 954 of the Act provides that the SEC must direct national securities exchanges to adopt clawback policies enabling the recovery of ...
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Heads Up Published: 2010-08-16 18:14:35... policies mandating the recovery (or "clawback") of "excess" incentive compensation ... policies mandating the recovery (or "clawback") of "excess" incentive compensation ...
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New Financial Regulatory Reform Bill Impacts Corporate Governance Published: 2010-03-23 20:13:07... Clawbacks A listed company would be required to develop and implement a policy providing: ... Section 304 of the Sarbanes-Oxley Act of 2002 (SOX) already contains a clawback provision. ...
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Blank Published: 2015-07-15 17:51:35... seeking adoption or disclosure of clawback policies (22), with the 13 proposals ... Other challenged proposals included the adoption of a clawback policy (4), the prohibition ...
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ISS and Glass Lewis Release Updates to Their Proxy Voting Guidelines Published: 2014-11-18 18:50:34... o whether the company maintains a clawback policy; and o whether the company has ... that it believes recoupment or "clawback" policies should be (i) triggered in the ...
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D E C E M B E Published: 2020-01-02 20:16:23... https://comptroller.nyc.gov/wp-content/uploads/2019/11/Investor-Letter-to-McDonalds-re.-Clawback-11.26.19.pdf The 2018 ... 88% mention they have a clawback policy These numbers are ...
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The Bribery Offenses Published: 2010-12-23 12:12:01... Clawbacks The Act requires that companies implement policies permitting the clawback of incentive compensation erroneously paid to company executives as a result of material ...
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Microsoft Word - 2024_05_02 FTC Bans Nearly All Noncompetes.docx Published: 2024-05-02 13:31:32... However, a typical clawback of a sign- on bonus where the worker terminates employment ... 2023 in connection with the implementation of Dodd Frank-compliant clawback policies. ...
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629864_003_RRD_BMK.PDF Published: 2014-02-10 15:10:16... proposals (i.e., pay-for-performance, clawbacks, compensation consultants, and conflicts ... such as through policies requiring clawbacks or imposing holding periods; * The ...
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The Proxy Season Field Guide 3rd Edition Published: 2013-08-09 00:07:01... proposals (i.e., pay-for-performance, clawback com- pensation consultants, and ... such as through policies requiring clawbacks or imposing holding periods; * The ...
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629864_003_RRD_BMK.PDF Published: 2014-05-20 16:37:13... proposals (i.e., pay-for-performance, clawbacks, compensation consultants, and conflicts ... such as through policies requiring clawbacks or imposing holding periods; * The ...
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Date Published: 2014-11-17 11:49:45... on Executive Compensation: One-Off Awards, Employee Stock Purchase Plans, and Clawbacks. ... In addition, Glass Lewis advises that clawback policies should be (i) triggered upon a ...
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Morrison & Foerster LLP Corporate Finance Practice The Proxy Published: 2016-01-13 13:16:27... proposals (i.e., pay-for-performance, clawbacks, compensation consultants, and conflicts ... such as through policies requiring clawbacks or imposing holding periods; * The ...
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2017-High-Yield-Bond-Study.pdf Published: 2017-05-02 15:11:10... percentage of deals permitting an equity clawback of greater than 35% of an issue during ... EMEA deals in 2016 permitted an equity clawback greater than 35% versus 35% in the U.S. ...
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Regaining Corporate Governance Balance.qxd Published: 2010-04-13 17:21:27... proxy vot- ing system, including the role of proxy advisory firms. * "Clawback" Policies. ... companies to consider whether a clawback policy is appropriate under the circumstances. ...
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The Dodd-Frank Act_Significant Impact on Public Companies.qxd Published: 2010-07-22 13:34:14... and Insights." * New compensation clawback policies applicable to all current and ... restating financial state- ments, with clawbacks applicable even when the officer did not ...
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ATLANTA CHICAGO CINCINNATI CLEVELAND COLUMBUS DAYTON NEW YORK... Published: 2020-05-27 19:44:14... Clawback of Lender Fees for Ineligible Borrowers Lenders also received what appears to be ... eligibility, lenders are now subject to clawback of substantial amounts of fees if the ...
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Microsoft Word - 9266_WeilBriefing_SEC_CG_2010-3-18_v2.doc Published: 2010-03-19 18:51:49... required information. (§ 953) Clawbacks of incentive-based compensation Not addressed. ... than the existing incentive compensation clawback provided by Section 304 of the ...
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PCAG Chart of Board Requirements Published: 2024-11-05 12:41:10... incentive-based compensation recovery (clawback). 122 Weil, Gotshal & Manges LLP 20 ... recovery (clawback). 120 Review of Compensation Committee Charter Not addressed. ...
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A U G U S Published: 2023-08-28 16:23:25... incentive-based compensation recovery (clawback). 122 Weil, Gotshal & Manges LLP 19 THE ... recovery (clawback). 120 Review of Compensation Committee Charter Not addressed. ...
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SEC Comment Letter Including Industry Insights Published: 2015-10-29 17:40:00... and the registrant's financial performance ("pay versus performance") and (2) a proposed rule 2 that would require registrants to adopt clawback policies on executive compensation. ...