Shearman & Sterling's "CEO Pay Ratio—Three-Year Refresher" speaks to the issue many companies may be facing this year in determining whether they need to select a new median employee for purposes of their CEO pay ratio calculation and disclosure based on significant changes in their employee population or compensation arrangements as a result of COVID-19 impacts, and - if so, how. The memo provides an overview of the disclosure requirements and associated inputs with a specific mention of C&DI Question 128C.04 (Regulation S-K, Section 128C — Item 402(u) Pay Ratio Disclosure) relating to furloughed workers.
See our recent report: "CEO Pay Ratio: COVID-19 Style" and additional information & resources on our Pay Ratio page. This post first appeared in the weekly Society Alert!