Survey Results: Clawback Policies


1. Has your company adopted a clawback policy: (Total responses: n=135)
(select only one)
n=13 (9.63%) Yes, we adopted a policy during 2010 for first time
n=7 (5.19%) Yes, we already had one before 2010 but we recently amended it
n=39 (28.89%) Yes, we already had one before 2010 and we intend to amend it soon
n=76 (56.30%) Not yet

2. If you answered "Not yet" to question above, do you intend to take any of the following steps in advance of adopting or amending a clawback policy: (Total responses: n=80)
(select all that apply, may total more than 100%)
n=18 (22.50%) Add provision into terms & conditions of certain incentive awards to enable a potential clawback
n=6 (7.50%) Have executives sign an independent document to enable a potential clawback of incentive awards generally
n=36 (45.00%) Add disclosure in proxy statement about the intention to adopt or amend a clawback policy after finalization of SEC rules implementing Section 954 of Dodd-Frank
n=32 (40.00%) None of the above

3. Does your company plan to adopt a new clawback policy or amend an existing policy: (Total responses: n=133)
(select only one)
n=10 (7.52%) Prior to finalization of SEC rules implementing Section 954 of Dodd-Frank
n=94 (70.68%) After finalization of SEC rules implementing Section 954 of Dodd-Frank
n=21 (15.79%) Don't know yet
n=8 (6.02%) No

4. Once fully completed or amended, does/will your clawback policy apply to: (Total responses: n=135)
(select only one)
n=35 (25.93%) Executive officers only
n=28 (20.74%) Group of key employees broader than executive officers
n=4 (2.96%) All employees
n=8 (5.93%) Some provisions of policy apply to certain group of employees and other provisions apply to other groups or all employees
n=60 (44.44%) Don't know yet

5. Once fully completed or amended, does/will your clawback policy apply to directors: (Total responses: n=134)
(select only one)
n=11 (8.21%) Yes, the entire clawback policy will apply to directors
n=1 (0.75%) Yes, but only part of clawback policy will apply to directors
n=45 (33.58%) No, it will not apply to directors
n=77 (57.46%) Don't know yet.