Shearman & Sterling LLP 90 | Clawback Policies
Common triggering events for the policies at the Top 100 Companies include:
12
17
22
28
7
11 11
2
11
Violation of restrictive covenants
(e.g., noncompetes, nonsolicitation
and confidentiality agreements)
Violation of law (including
embezzlement, theft and bribery)
Violation of company policy
(including code of conduct and code
of ethics)
Acts resulting in reputational,
financial or other harm to
the company
Failure of risk management
Failure to supervise
General fraud or misconduct
Termination for cause or misconduct
Other detrimental activities
of the Top 100 Companies publicly disclose that they
maintain a detrimental conduct clawback policy
54
$
