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SEC Commissioner Peirce on Flaws in New Clawback Rules

Reynolds Holding

After quoting from the Senate Banking Committee Report that the clawback provision “is required to apply to executive officers, a very limited number of employees, and is not required to apply to other employees,” [6] the Commission adopts an intentionally broad definition of “executive officer.” [7]

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ESG A Valuation Framework

Value Scope

How do you justify making substantial investments and fundamental changes to corporate structures and culture without empirical evidence that it will make a direct impact on shareholder value, total shareholder return, net present value, and individual rates of return? . These are fair questions.