Reynolds Holding

NOVEMBER 30, 2023

07 Question: In each of 2020 and 2021, a registrant provided the same list of companies as a peer group in its Compensation Discussion & Analysis (“CD&A”) under Item 402(b) but provided a different list of companies in its CD&A for 2022. In what circumstances is such market capitalization-based weighting required?

Compliance 40

Compliance Total Shareholder Return Dividends Market Capitalization 40

Cooley M&A

JANUARY 30, 2024

Globally, 229 campaigns launched in 2023, just under 2022 campaign levels, ushering in the most active two-year period on record. [1] 1] Activism in Europe was a core driver of activity, representing 28% of all campaigns and a 30% increase from 2022. [2] 4] Activists won 134 board seats globally in 2023, a 30% increase from 2022.

Market Capitalization 52

Market Capitalization Equity Marketability Total Shareholder Return 52

Reynolds Holding

SEPTEMBER 6, 2022

On August 25, 2022, the U.S. The SEC issued proposed pay-versus-performance rules in 2015 and reopened the comment period on the proposed rules in January 2022. Peer group TSR will be weighted based on the initial market capitalization of each peer group company as of the beginning of the earliest year included in the table.

Total Shareholder Return 45

Total Shareholder Return Equity Dividends Market Capitalization 45