Deadline To Adopt SEC-Compliant Clawback Policy Is Fast Approaching

New York, N.Y. (November 14, 2023) - On October 26, 2022, the Securities and Exchange Commission ("SEC") adopted Rule 10D-1 under the Securities Exchange Act of 1934 ("Exchange Act") implementing section 954 of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 (Dodd-Frank Act), which required the SEC and the national securities exchanges to establish listing standards that require publicly listed companies to adopt and comply with a "clawback policy" for the recovery of erroneously awarded incentive-based compensation paid to their executive officers.

Rule 10D-1 went into effect in January 2023. The New York Stock Exchange ("NYSE") and Nasdaq listing standards were subsequently approved by the SEC in June 2023 and became effective on October 2, 2023.