Maya Tanaka· Sales Compensation Manager, Calibre Software
Posted in New York Chapter ·
We adopted our recovery policy when the listing standards came in, and I thought that was the end of it. It was not. Our compensation committee has now asked whether the discretionary policy that sits alongside it, the one covering misconduct without a restatement, should be widened to time-vested equity.
As we read it, the mandatory policy only reaches incentive pay tied to financial measures, so anything beyond that is our choice. Has anyone here extended recovery to time-based awards, and how did executives react?
I can bring our anonymised committee paper to the next Midtown breakfast if that helps.
0 reactions · 1 reply · 7 views
Amara ZhangGRS
Director, Total Rewards, Copperfield Mining
We kept two separate documents on our counsel's advice: the mandatory policy drafted tightly to the rule, and a broader misconduct policy covering time-vested RSUs with a three-year lookback. The committee has discretion under the second one and none under the first.
Executives pushed back less than I expected, mostly because several peers in our proxy group had already done the same.
