Reynolds Holding

NOVEMBER 30, 2023

On November 21, 2023, the staff of the Securities and Exchange Commission’s (SEC’s) Division of Corporation Finance issued eight new Compliance & Disclosure Interpretations (C&DIs), and revised two previously issued C&DIs, relating to the final pay-versus-performance (PVP) disclosure rules adopted last year. Answer: No.

Compliance 40

Compliance Total Shareholder Return Dividends Market Capitalization 40

Reynolds Holding

MARCH 1, 2023

Deadline for Compliance What’s next: Once published in the Federal Register, there will be a public comment period of 21 days, and then the SEC must approve both listing standards. 14 prohibits the initial or continued listing of any security of a company that is not in compliance with the clawback rule. New Section 303A.14

Compliance 45

Compliance Total Shareholder Return Finance Equity 45

Harvard Corporate Governance

OCTOBER 9, 2023

On August 25, 2023, two SEC compliance and disclosure interpretations (“C&DI”) were issued related to these quarterly disclosures. [1] SRCs with a June 30 fiscal year-end have until their Form 10-K or 20-F for the fiscal year ending June 30, 2025 to provide their first annual disclosures. 1] C&DI 133A.01

Total Shareholder Return 188

Total Shareholder Return Equity Compliance Marketability 188