Shearman & Sterling LLP 86 | Say-on-Pay
FAST FACTS
SAY-ON-PAY PROXY DISCLOSURES
SAY-ON-FREQUENCY
VOTING RESULTS
10
companies that held
say-on-frequency votes
in 2018
Of the
ALL
opted for annual
say-on-pay voting
OF THE TOP 100 COMPANIES:
Noted that the company reviewed the
results and elected not to significantly
change the compensation program
Disclosed the approval rate for the
previous year's say-on-pay vote
Noted changes made to the
compensation program in response
to the say-on-pay vote
Provided no say-on-pay disclosures
The Dodd-Frank Act requires companies to disclose whether and how the prior
year's say-on-pay voting results were considered in making compensation
decisions. Many companies went beyond this requirement.
49
17
85
7
