Skadden Discusses New SEC Pay-Versus-Performance Compliance & Disclosure Interpretations
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.
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