New Data on Clawback Policies

A recent PWC study of 100 large companies revealed that the two most common clawback policy triggers are misconduct and restatement of financials—which are disclosed in 84% and 68% of policies, respectively. Risk management, performance, and compliance violations were the most seldom used triggers, with risk management predominantly used by financial companies. Many companies initially adjusted their clawback guidelines following the Sarbanes-Oxley Act of 2002, and more are predicted to do so following the finalization of the Dodd-Frank clawback rule, expected later this year.

Clawback Policies Vary by Company, Industry: PwC (WSJ CFO Journal (subscription required))

Executive Compensation: Clawbacks—2013 Proxy Disclosure Study (PricewaterhouseCoopers LLP)