Harvard Corporate Governance

OCTOBER 9, 2023

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. Quarterly Disclosures. With respect to proxy disclosure, C&DI 120.27 The rule generally requires disclosure of five years of pay versus performance data.

Total Shareholder Return 188

Total Shareholder Return Equity Compliance Marketability 188

Reynolds Holding

MARCH 1, 2023

Financial reporting measures also include stock price and total shareholder return (TSR). 3 Example : If the restatement is required in 2027, then the clawback would apply to compensation received in 2024, 2025 and 2026.A What if the incentive-based compensation is based on stock price or Total Shareholder Return (TSR)?

Compliance 45

Compliance Total Shareholder Return Finance Equity 45

Reynolds Holding

NOVEMBER 30, 2023

With respect to a registrant providing initial Pay versus Performance disclosure in its 2023 proxy statement for three years (as permitted by Instruction 1 to Item 402(v) of Regulation S-K), may the registrant present the peer group total shareholder return for each of the three years using the 2022 peer group? Answer: No.

Compliance 40

Compliance Total Shareholder Return Dividends Market Capitalization 40