On August 5, 2015 the SEC adopted the pay ratio disclosure rule mandated by Dodd-Frank requiring public companies to “disclose the ratio of the compensation of its chief executive officer (CEO) to the median compensation of its employees”. Advocates suggest that opening up the books publicly enable shareholders to make smarter decisions on say on pay proposals and that disclosure is long overdue in the interest of greater responsibility and transparency for publicly traded companies. The new rule presents not just concerns around sensitive company financials, but also the likelihood of costs associated to analyze and produce the necessary calculations and documentation. With annual reports required on or after January 1, 2017, companies are now grappling with the scope of all requirements. The new rule is raising unique, albeit controversial, elements to how far companies are required to go and should go in the interest of transparency. Do corporate values on ethics and responsibility perfectly align with the pay-gap rule, outweighing the costs to the company? What are the data privacy considerations? What role might compliance and ethics executives have now or in years to come? The executive panel for this timely session will break down the requirements while presenting compelling cases on both sides of the issue.
- Erica Salmon Byrne, Executive Vice President, Compliance & Governance Services, Ethisphere
- Roger Brossy, Managing Director, Semler Brossy Consulting Group
- Timothy P. Olson, Senior Corporate Counsel and Corporate Secretary, NorthWestern Energy
- Carey Roberts, Deputy General Counsel, Chief Compliance Officer & Corporate Secretary, Marsh & McLennan Companies, Inc.