Issue link: https://digital.shearman.com/i/1512772
Shearman & Sterling LLP Clawback Policies | 100 6 Named executive officers only All employees (or all participants in the plans or programs subject to the clawback policy) All executive officers Not disclosed 2 Section 16 officers only 64 The following individuals are subject to the voluntary financial-related clawbacks at the top 100 companies 9 3 10 Senior Management of the Top 100 Companies expressly disclose that the clawback policy applies to former employees 17 Covered Persons The threshold issue is determining whose compensation is subject to a clawback. Under the new Dodd-Frank clawback policy requirement, all current and former executive officers are covered.