Corporate Governance

2023 Corporate Governance Survey

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Shearman & Sterling LLP Clawback Policies | 102 General fraud or misconduct Violation of restrictive covenants (e.g., noncompetes, nonsolicitation and confidentiality agreements) Acts resulting in reputational, financial or other harm to the company Violation of company policy (including code of conduct and code of ethics) Termination for cause or misconduct Violation of law (including embezzlement, theft and bribery) Failure of risk management Common triggering events for the policies at the Top 100 Companies include 83 of the Top 100 Companies publicly disclose that they maintain a detrimental conduct clawback policy 21 23 3 11 20 9 56 $

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