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Recent SEC Settlement Reinforces Need for Public Companies to Properly Disclose Perks
Stevens & Lee Aug. 14, 2018 "On July 2, 2018, the SEC instituted a cease and desist order against The Dow Chemical Company for failing to properly disclose $3 million in perquisites that Dow Chemical provided to its chief executive officer.... Dow Chemical agreed to pay a civil monetary penalty of $1.75 million and to complete certain remedial undertakings.... Dow Chemical's circumstances should remind each public company that it needs to carefully identify and analyze each benefit that it provides to its NEOs to determine whether it requires disclosure as a perquisite." |
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