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