In addition to noting certain major institutional investors' and ISS's positions/guidelines on company clawback policies, Pillsbury's "The State of Play on Clawbacks and Forfeitures Based on Misconduct" narratively and graphically (below) compares the clawbacks and forfeiture policies of 10 major Silicon Valley employers:
The memo also includes sample equity forfeiture and clawback provisions - the latter of which tracks ISS Equity Plan Scorecard requirements.
For those considering implementation or expansion of their policies - whether in anticipation of the SEC adopting a rule or otherwise, the memo imparts useful information and data to inform companies' approaches.
See this MetroNews post, and additional information & resources on our Clawbacks page. This post first appeared in the weekly Society Alert!