Corporate Governance

2023 Corporate Governance Survey

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Shearman & Sterling LLP 103 | CEO Pay Ratio 68 of the Top 100 Companies used the same median employee as the prior year The CEO pay ratio rules permit companies to use the same median employee for up to three years. This year we saw an increase in pay ratios below 400:1, and most CEO pay ratios remained below 400:1. 2023 represented the sixth proxy season that companies were required to disclose the ratio of CEO pay to pay of the median employee. Pay Ratios Less than 100:1 100:1 – 199:1 200:1 – 299:1 300:1 – 399:1 400:1 – 499:1 500:1 – 699:1 700:1 – 899:1 Over 900:1 24 9 26 16 7 5 5 8 Data CEO Pay Ratio of the Top 100 Companies provided an alternative ratio and often provided the alternative ratio to exclude a special equity award that was granted to the CEO. 6

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