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ARTICLE · 30 JANUARY 2018

Pay Ratio To Be Key Issue In 2018 Proxy Season

In addition to reviewing the SEC's latest guidance, those seeking sample disclosures may refer to the 2017 proxy statements of companies that voluntarily provided pay ratio disclosures.

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Despite much hope that the day would never come, the arrival of 2018 means that most public companies will be required to comply with the SEC's pay ratio disclosure rule in their next annual meeting proxy statement or Form 10-K. In addition to reviewing the SEC's latest guidance, those seeking sample disclosures may refer to the 2017 proxy statements of companies that voluntarily provided pay ratio disclosures.

Disclosures last year included:

NorthWestern notes, "We believe executive pay must be internally consistent and equitable to motivate our employees to create shareholder value. We are committed to internal pay equity, and the Compensation Committee monitors the relationship between the pay our executive officers receive and the pay

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