Corporate Governance

2018 Corporate Governance & Execution Compensation Survey

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HEDGING AND PLEDGING POLICIES Shearman & Sterling LLP Hedging and Pledging Policies | 103 WHAT ARE THE TERMS OF THE PLEDGING POLICY?* *Five of the Top 100 Companies provide for an outright prohibition other than in limited circumstances. WHAT ARE THE TERMS OF THE HEDGING POLICY? HEDGING AND PLEDGING POLICIES 82 93 of the Top 100 Companies maintain pledging policies of the Top 100 Companies maintain hedging policies Require Approval Outright Prohibition All 93 of the Top 100 Companies Prohibit Hedging Outright 10 67 93

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