Annual Corporate Governance & Executive Compensation Survey

2018 Corporate Governance Survey

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Shearman & Sterling LLP 88 | Clawback Policies COVERED PERSONS The threshold issue is determining whose compensation is subject to a clawback. Clawbacks mandated under the proposed SEC rule will apply to all current and former Section 16 officers. The following individuals are subject to the voluntary financial-related clawbacks at the Top 100 Companies: 1 2 53 21 10 5 Named Executive Officers ( NEOs) Only All Officers All Executive Officers All Employees (or all participants in the plans or programs subject to the clawback policy) Senior Employees Not disclosed 2 of the Top 100 Companies expressly disclose that the clawback policy applies to former employees or executives

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