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Pay Ratio Disclosures: Annual Proxy Statements Filed in 2021 May Need a New Median Employee Determination
Thompson Coburn
[Guidance Overview] Oct. 12, 2020 "The final rule [requires] each company to make a new determination of the company's median employee at least once every three years.... The disclosures in the annual proxy statement must describe the methodology used to identify the median employee and any material assumptions, adjustments or estimates used.... [W]hen calculating the median employee's annual total compensation, companies must use the same rules they apply to determining the CEO's annual total compensation[.]" |
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