In October 2022, the SEC adopted a final rule directing the exchanges to mandate development, implementation, disclosure, and filing of incentive-based compensation clawback policies for required accounting restatements by listed companies. DragonGC’s analysis of 401 S&P 500 companies that disclosed their compensation clawback policies as of early May 2024 revealed the following practices as respects non-restatement triggers:
The vast majority of companies include triggers beyond those required by the SEC rule and corresponding listing standards (NYSE | Nasdaq).
The report includes descriptions and disclosure examples associated with each of the foregoing triggers.
Access the report on a complimentary basis here.
See “Most large companies exceeding SEC requirements on clawback policies” (Governance Intelligence) and additional resources on our Clawbacks page.
This content first appeared in the Society Alert!