Survey Results: Clawback Policies
|
1. Has your company adopted a clawback policy: (Total responses: n=135)
(select only one) |
| n=13 (9.63%) |
Yes, we adopted a policy during 2010 for first time |
| n=7 (5.19%) |
Yes, we already had one before 2010 but we recently amended it
|
| n=39 (28.89%) |
Yes, we already had one before 2010 and we intend to amend it
soon |
| n=76 (56.30%) |
Not yet |
2. If you answered "Not yet" to question above, do you intend to take
any of the following steps in advance of adopting or amending a clawback
policy: (Total responses: n=80)
(select all that apply, may total more than 100%) |
| n=18 (22.50%) |
Add provision into terms & conditions of certain incentive awards
to enable a potential clawback |
| n=6 (7.50%) |
Have executives sign an independent document to enable a
potential clawback of incentive awards generally |
| n=36 (45.00%) |
Add disclosure in proxy statement about the intention to adopt or
amend a clawback policy after finalization of SEC rules implementing
Section 954 of Dodd-Frank |
| n=32 (40.00%) |
None of the above |
3. Does your company plan to adopt a new clawback policy or amend an
existing policy: (Total responses: n=133)
(select only one) |
| n=10 (7.52%) |
Prior to finalization of SEC rules implementing Section 954 of
Dodd-Frank |
| n=94 (70.68%) |
After finalization of SEC rules implementing Section 954 of
Dodd-Frank |
| n=21 (15.79%) |
Don't know yet |
| n=8 (6.02%) |
No |
4. Once fully completed or amended, does/will your clawback policy
apply to: (Total responses: n=135)
(select only one) |
| n=35 (25.93%) |
Executive officers only |
| n=28 (20.74%) |
Group of key employees broader than executive officers |
| n=4 (2.96%) |
All employees |
| n=8 (5.93%) |
Some provisions of policy apply to certain group of employees and
other provisions apply to other groups or all employees |
| n=60 (44.44%) |
Don't know yet |
5. Once fully completed or amended, does/will your clawback policy
apply to directors: (Total responses: n=134)
(select only one) |
| n=11 (8.21%) |
Yes, the entire clawback policy will apply to directors |
| n=1 (0.75%) |
Yes, but only part of clawback policy will apply to directors
|
| n=45 (33.58%) |
No, it will not apply to directors |
| n=77 (57.46%) |
Don't know yet. |
|
