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An early look at the second year of CEO pay ratio disclosures shows that the ratios held steady for the overall sample, while on a companybycompany basis the ratio was quite volatile.
The 2019 Proxy Season has begun, and Compensation Advisory Partners (CAP) has done a comprehensive analysis of the second year of CEO pay ratio disclosures to identify what has changed and what trends are emerging. At a high level, CAP has found the following:
 CEO Pay Ratio: While CEO pay ratio summary statistics (e.g., 25th percentile, median, and 75th percentile) were flat across the sample, twothirds of the sample companies had pay ratios that fluctuated up or down by more than 10 percent. The significant volatility in individual company pay ratios is masked in the overall sample, so proxy readers should not be surprised if a company’s pay ratio moved yearoveryear.
 CEO Pay: CEO compensation increased 7 percent at median with twothirds of CEO pay fluctuating by more than 10 percent. This may be driven by incentive compensation changing year to year, by CEO transitions and by changes in pension value calculations where applicable.
 Median Employee: Only 36 percent of companies used the same median employee yearoveryear. For the companies that use the same median employee, the pay of that employee went up 7 percent at median. Where companies selected a new median employee, the yearoveryear change in pay was 4 percent at median. This indicates that companies that want to maintain a lower CEO pay ratio may be better off keeping the same median employee from year to year if possible.
 Additional Disclosures: Despite interest expressed by some institutional shareholders in greater disclosure about the workforce, only 16 percent of companies disclosed additional information about the median employee (e.g., geographic location, role with the company, fulltime vs. parttime, etc.). This is up from 12 percent of companies providing additional disclosures last year.
Methodology
CAP analyzed 201 of the first proxies filed in 2019 in order to study developing trends and examine differences from prioryear disclosures. The median company revenue of this sample is $2.1 billion. Detailed exhibits of findings are shown in appendix below this report.
Pay Ratio
CEO pay ratio at median, 25th and 75th percentiles are stable for this sample of companies when compared to the prior year.
Summary Statistics 
2017 
2018 
% Change 
75th Percentile 
165x 
165x 
0% 
Median 
79x 
78x 
1% 
25th Percentile 
40x 
40x 
+1% 
When looking at this sample on a companymatched basis, the percentage change of pay ratio was flat at median (1%), 25th percentile (+1%) and 75th percentile (0%). Despite the flat yearoveryear summary statistics, significant volatility in the pay ratio occurs at the individual company level, driven by both changes in pay levels for the CEO and in pay levels for the median employee. On a companymatched basis, about half of the sample had increases in the pay ratio, and half had decreases. When looking at the percentage change in the pay ratio, CAP found that twothirds of companies had yearoveryear changes in the pay ratio of more than +/10 percent. This shows that while the total sample may seem unchanged yearoveryear, individual companies have a good amount of variability that ends up being masked when the pay ratio data are viewed in aggregate. This individual company variation will likely be evident in coming years as well, as CEO and median employee pay can fluctuate significantly year to year. These factors coupled with the variety of methodologies that can be used continue to make drawing meaningful comparisons across companies difficult.
CEO and Median Employee Pay
CEO pay increased 7 percent at median, while the pay of the median employee increased 5 percent at median. While the increases in pay were similar at median, there was much greater volatility in CEO pay yearoveryear with twothirds of CEO pay fluctuating by more than 10 percent compared to onethird of median employees’ pay. This can be most easily explained by CEO’s having a much larger percentage of incentive compensation, generally, which may vary in magnitude year to year. Another source of fluctuation could be at companies where the CEO and/or the median employee participate in a pension plan, as increases to the discount rate used to value pension benefits can drive down Summary Compensation Table (SCT) pay. CEO and median employee pay moved in the same direction in 60 percent of companies, which shows at least some correlation between CEO pay and that of the typical employee. A correlation is more likely when the median employee is bonus and/or equity eligible, as more of his or her compensation is linked with the company and, therefore, the CEO’s.
Approximately 35 percent of companies used the same median employee for computing the CEO pay ratio as in the prior year. When a company used the same median employee as last year, the pay for that median employee increased between 7 percent and 8 percent at the median, 25th and 75th percentiles. This represents larger increases than when a company selected a new median employee, with median employee pay remaining relatively flat (0 to 4%). This indicates that reselecting the median employee will more likely result in decreased or flat pay for the median employee, as salary typically increases over tenure, and incentive compensation tends to be modest for employees at this level. A decrease in median employee pay by more than 3 percent is twice as prevalent (27% versus 13%) at companies reselecting their median employee. When a company selects a new median employee, they have the option of selecting a substantially similar employee from the previous year, seen approximately 20% of the time, or rerunning the selection analysis in the current year, seen approximately 80% of the time.
Median Employee Pay 

Summary Statistics 
Same Median Employee 
Chose New Median Employee 

2017 
2018 
% Change 
2017 
2018 
% Change 

75th Percentile 
$80,354 
$86,352 
+7% 
$84,883 
$86,046 
+1% 
Median 
$59,248 
$63,665 
+7% 
$58,658 
$60,726 
+4% 
25th Percentile 
$46,163 
$49,976 
+8% 
$44,980 
$44,974 
0% 
Disclosure Features
Much of the structure of pay ratio disclosure remained parallel with last year. Approximately 60 percent of companies made reference to the prioryear disclosure in some way. However, only about 15 percent of these companies cited last year’s pay ratio, CEO pay or median employee pay. The location of the payratio disclosure within the proxy statement was nearly identical, with more than 90 percent of the disclosures being within or after the compensation tables. The inclusion of nondiscriminatory benefits (i.e., benefits such as health insurance that are provided to all employees and are not included in CEO pay in the SCT) in the CEO and median employee pay calculation remained steady, with an estimated 14 percent of companies including nondiscriminatory benefits in the calculation this year, compared with approximately 13 percent of the S&P 500 last year. Including these nondiscriminatory benefits in both pay calculations deflates CEO pay ratio as the proportion of pay this makes up is systematically larger for the median employee than for the CEO. The measurement date used, adjustments to employee compensation (cost of living, annualizing compensation), use of a comparability disclaimer and statistical sampling were all very stable as well, with only a handful of companies adopting or removing these features. The use of supplemental ratios, descriptors of the median employee, and exemptions from the employee population had more varied disclosures when compared to prior year.
Supplemental ratios
Supplemental ratios were disclosed at roughly the same rate yearoveryear, with approximately 10 percent of companies providing a supplemental ratio. One supplemental ratio is by far the most prevalent practice. Using an alternate CEO compensation calculation continued to be the most prevalent (63%) driver of disclosing a supplemental ratio. Where this feature differed was in the consistency of individual companies between last year and this year. If the supplemental ratio was disclosed in order to explain a onetime event (e.g. special equity award, CEO transition) then that company would likely not have a supplemental ratio for this year. If the company used a supplemental ratio to show an alternate CEO compensation amount (e.g. exclude pension value) or an alternate employee demographic (e.g. exclude nonU.S. employees), then the supplemental ratio was almost always disclosed again.
Description of Median Employee
This year’s sample of early filers saw a slight uptick in the percentage of companies (16%) that provided any description of their median employee compared to last year’s earlyfiler sample (12%) and the S&P 500 (14%). These descriptions vary in detail but often provide insights into who the median employee is. Geographic location of employment (76%) and the role within the company (48%) are the two most common descriptors, but these are often paired and/or supplemented with detail around employment type (fulltime versus parttime) and pay type (salaried versus hourly).
Exemptions from Employee Population
Similar to the use of supplemental ratios, the use of exemptions from the employee population when determining the median employee remained consistent (~37%) between last year and this year. Applying multiple exemptions is not uncommon (~20%), and the De Minimis exemption, whereby a company may exclude up to 5 percent of its nonU.S. employee workforce, continues to be the most commonly (64%) used case. Other exclusions included not considering employees gained from mergers and acquisitions (M&A) activity (33%), contractors (19%) and employees on a leave of absence (5%). When companies did not make the same exemptions again this year, either the company’s nonU.S. portion of its employee population is now over 5 percent, or an M&A event did not occur.
Looking Forward
Overall, the CEO pay ratio did not change materially at median. However, a closer look at the companymatched data shows that significant volatility in the CEO pay ratio occurred at individual companies. While there has not yet been a significant increase in supplemental disclosures outside of the proxy statement or additional disclosures about the median employee, such information may be disclosed more frequently in the future as pressure mounts from shareholders and institutional investors. Looking beyond the CEO pay ratio disclosure itself, shareholders and institutional investors definitely want more disclosure about companies’ human capital. Whether this information is provided through the CEO pay ratio disclosure or elsewhere remains to be seen.
Appendix
Year 2 vs Year 1 – Same Company Data
Overview – Total Sample
CEO Pay Ratio 
2017 
2018 
% Change 
Summary Statistics (n=201) 

Maximum 
2483x 
2508x 
+1% 
90th Percentile 
341x 
301x 
12% 
75th Percentile 
165x 
165x 
0% 
Median 
79x 
78x 
1% 
25th Percentile 
40x 
40x 
+1% 
10th Percentile 
18x 
20x 
+13% 
Minimum 
2x 
3x 
+47% 
CEO Pay 
2017 
2018 
% Change 
Summary Statistics (n=201) 

Maximum 
$42,247,984 
$129,499,005 
+207% 
90th Percentile 
$15,845,991 
$15,695,189 
1% 
75th Percentile 
$10,253,787 
$9,989,992 
3% 
Median 
$5,060,220 
$5,422,777 
+7% 
25th Percentile 
$2,347,314 
$2,726,774 
+16% 
10th Percentile 
$1,072,999 
$1,333,951 
+24% 
Minimum 
$339,165 
$306,000 
10% 
Median Employee Pay 
2017 
2018 
% Change 
Summary Statistics (n=201) 

Maximum 
$964,005 
$256,300 
73% 
90th Percentile 
$123,347 
$118,209 
4% 
75th Percentile 
$83,153 
$86,046 
+3% 
Median 
$59,092 
$61,782 
+5% 
25th Percentile 
$45,409 
$47,252 
+4% 
10th Percentile 
$34,967 
$35,724 
+2% 
Minimum 
$4,828 
$4,563 
5% 
Overview – Disclosure Features
Makes Any Reference to Year 1 Disclosure 
Prevalence 
Percentage 
Summary Statistics (n=201) 

Yes 
117 
58% 
No 
84 
42% 
Mentions Year 1 Pay Ratio, CEO Pay, or Median EE Comp 
Prevalence 
Percentage 
Summary Statistics (n=201) 

Yes 
31 
15% 
No 
170 
85% 
Uses Same Median Employee as Year 1 
Prevalence 
Percentage 
Summary Statistics (n=201) 

Yes 
73 
36% 
No – Reran Analysis 
105 
52% 
No – Used Similar Employee as Year 1 
23 
11% 
Discloses Change(s) in Methodology from Year 1 
Prevalence 
Percentage 
Summary Statistics (n=201) 

Yes 
3 
1% 
No 
198 
99% 
CEO Pay & Median Employee Pay Movement from Year 1 
Prevalence 
Percentage 
Summary Statistics (n=201) 

Both Increase 
91 
45% 
CEO Pay Increased & Median Employee Pay Decreased 
29 
14% 
CEO Pay Decreased & Median Employee Pay Increased 
52 
26% 
Both Decrease 
29 
14% 
Overview – Companies Choosing To Use The Same Median Employee
CEO Pay Ratio 
2017 
2018 
% Change 
Summary Statistics (n=73) 

Maximum 
1830x 
1511x 
17% 
75th Percentile 
157x 
147x 
6% 
Median 
90x 
84x 
7% 
25th Percentile 
45x 
44x 
3% 
Minimum 
10x 
7x 
30% 
CEO Pay 
2017 
2018 
% Change 
Summary Statistics (n=73) 

Maximum 
$42,247,984 
$129,499,005 
+207% 
75th Percentile 
$10,845,759 
$9,793,261 
10% 
Median 
$5,060,220 
$5,658,238 
+12% 
25th Percentile 
$2,926,176 
$2,828,289 
3% 
Minimum 
$545,525 
$607,332 
+11% 
Median Employee Pay 
2017 
2018 
% Change 
Summary Statistics (n=73) 

Maximum 
$186,172 
$191,473 
+3% 
75th Percentile 
$80,186 
$85,704 
+7% 
Median 
$59,092 
$62,150 
+5% 
25th Percentile 
$46,370 
$50,226 
+8% 
Minimum 
$5,237 
$6,348 
+21% 
Overview – Companies Selecting a New Median Employee
CEO Pay Ratio 
2017 
2018 
% Change 
Summary Statistics (n=128) 

Maximum 
2483x 
2508x 
+1% 
75th Percentile 
172x 
186x 
+8% 
Median 
76x 
73x 
4% 
25th Percentile 
33x 
36x 
+10% 
Minimum 
2x 
3x 
+47% 
CEO Pay 
2017 
2018 
% Change 
Summary Statistics (n=128) 

Maximum 
$31,082648 
$29,118,118 
6% 
75th Percentile 
$10,030,633 
$10,168,771 
+1% 
Median 
$4,933,902 
$5,172,842 
+5% 
25th Percentile 
$2,175,523 
$2,662,381 
+22% 
Minimum 
$339,165 
$306,000 
10% 
Median Employee Pay 
2017 
2018 
% Change 
Summary Statistics (n=128) 

Maximum 
$964,005 
$256,300 
73% 
75th Percentile 
$84,883 
$86,046 
+1% 
Median 
$58,659 
$60,726 
+4% 
25th Percentile 
$44,980 
$44,974 
0% 
Minimum 
$4,828 
$4,563 
5% 
How Pay and Pay Ratio Changed – Total Sample
How Did Pay Ratio Change? 
Prevalence 
Percentage 
Summary Statistics (n=201) 

Increased 
100 
50% 
Decreased 
96 
48% 
Remained the Same 
5 
2% 
How Did CEO Pay Change? 
Prevalence 
Percentage 
Summary Statistics (n=201) 

Increased 
119 
59% 
Decreased 
81 
40% 
Remained the Same 
1 
0% 
How Did Median Employee Pay Change? 
Prevalence 
Percentage 
Summary Statistics (n=201) 

Increased 
143 
71% 
Decreased 
58 
29% 
Remained the Same 
0 
0% 
How Pay and Pay Ratio Changed – Total Sample
How Did Pay Ratio Change? 
Prevalence 
Percentage 
Summary Statistics (n=201) 

Increased by 25% or more 
39 
19% 
Increased by 10% to 25% 
30 
15% 
Increased by 3% to 10% 
22 
11% 
Changed between 3% to 3% 
24 
12% 
Decreased by 3% to 10% 
19 
9% 
Decreased by 10% to 25% 
43 
21% 
Decreased by 25% or more 
24 
12% 
How Did CEO Pay Change? 
Prevalence 
Percentage 
Summary Statistics (n=201) 

Increased by 25% or more 
42 
21% 
Increased by 10% to 25% 
39 
19% 
Increased by 3% to 10% 
28 
14% 
Changed between 3% to 3% 
24 
12% 
Decreased by 3% to 10% 
17 
8% 
Decreased by 10% to 25% 
28 
14% 
Decreased by 25% or more 
23 
11% 
How Did Median Employee Pay Change? 
Prevalence 
Percentage 
Summary Statistics (n=201) 

Increased by 25% or more 
11 
5% 
Increased by 10% to 25% 
34 
17% 
Increased by 3% to 10% 
66 
33% 
Changed between 3% to 3% 
46 
23% 
Decreased by 3% to 10% 
23 
11% 
Decreased by 10% to 25% 
12 
6% 
Decreased by 25% or more 
9 
4% 
How Pay and Pay Ratio Changed – Companies Choosing To Use The Same Median Employee
How Did Pay Ratio Change? 
Prevalence 
Percentage 
Summary Statistics (n=73) 

Increased 
27 
37% 
Decreased 
43 
59% 
Remained the Same 
3 
4% 
How Did CEO Pay Change? 
Prevalence 
Percentage 
Summary Statistics (n=73) 

Increased 
42 
58% 
Decreased 
31 
42% 
Remained the Same 
0 
0% 
How Did Median Employee Pay Change? 
Prevalence 
Percentage 
Summary Statistics (n=73) 

Increased 
61 
84% 
Decreased 
12 
16% 
Remained the Same 
0 
0% 
How Pay and Pay Ratio Changed – Companies Choosing To Use The Same Median Employee
How Did Pay Ratio Change? 
Prevalence 
Percentage 
Summary Statistics (n=73) 

Increased by 25% or more 
11 
15% 
Increased by 10% to 25% 
5 
7% 
Increased by 3% to 10% 
7 
10% 
Changed between 3% to 3% 
10 
14% 
Decreased by 3% to 10% 
8 
11% 
Decreased by 10% to 25% 
18 
25% 
Decreased by 25% or more 
14 
19% 
How Did CEO Pay Change? 
Prevalence 
Percentage 
Summary Statistics (n=73) 

Increased by 25% or more 
13 
18% 
Increased by 10% to 25% 
11 
15% 
Increased by 3% to 10% 
11 
15% 
Changed between 3% to 3% 
10 
14% 
Decreased by 3% to 10% 
8 
11% 
Decreased by 10% to 25% 
9 
12% 
Decreased by 25% or more 
11 
15% 
How Did Median Employee Pay Change? 
Prevalence 
Percentage 
Summary Statistics (n=73) 

Increased by 25% or more 
6 
8% 
Increased by 10% to 25% 
13 
18% 
Increased by 3% to 10% 
33 
45% 
Changed between 3% to 3% 
12 
16% 
Decreased by 3% to 10% 
4 
5% 
Decreased by 10% to 25% 
5 
7% 
Decreased by 25% or more 
0 
0% 
How Pay and Pay Ratio Changed – Companies Selecting a New Median Employee
How Did Pay Ratio Change? 
Prevalence 
Percentage 
Summary Statistics (n=128) 

Increased 
73 
57% 
Decreased 
53 
41% 
Remained the Same 
2 
2% 
How Did CEO Pay Change? 
Prevalence 
Percentage 
Summary Statistics (n=128) 

Increased 
77 
60% 
Decreased 
50 
39% 
Remained the Same 
1 
1% 
How Did Median Employee Pay Change? 
Prevalence 
Percentage 
Summary Statistics (n=128) 

Increased 
82 
64% 
Decreased 
46 
36% 
Remained the Same 
0 
0% 
How Pay and Pay Ratio Changed – Companies Selecting a New Median Employee
How Did Pay Ratio Change? 
Prevalence 
Percentage 
Summary Statistics (n=128) 

Increased by 25% or more 
28 
22% 
Increased by 10% to 25% 
25 
19% 
Increased by 3% to 10% 
15 
12% 
Changed between 3% to 3% 
14 
11% 
Decreased by 3% to 10% 
11 
9% 
Decreased by 10% to 25% 
25 
19% 
Decreased by 25% or more 
10 
8% 
How Did CEO Pay Change? 
Prevalence 
Percentage 
Summary Statistics (n=128) 

Increased by 25% or more 
29 
23% 
Increased by 10% to 25% 
28 
22% 
Increased by 3% to 10% 
17 
13% 
Changed between 3% to 3% 
14 
11% 
Decreased by 3% to 10% 
9 
7% 
Decreased by 10% to 25% 
19 
15% 
Decreased by 25% or more 
12 
9% 
How Did Median Employee Pay Change? 
Prevalence 
Percentage 
Summary Statistics (n=128) 

Increased by 25% or more 
5 
4% 
Increased by 10% to 25% 
21 
16% 
Increased by 3% to 10% 
33 
26% 
Changed between 3% to 3% 
34 
27% 
Decreased by 3% to 10% 
19 
15% 
Decreased by 10% to 25% 
7 
5% 
Decreased by 25% or more 
9 
7% 
Early Disclosures Year 2 vs Year 1
Overview – Total Sample
CEO Pay Ratio 
Revenue ($mm) 
CEO Pay 
Median Employee Pay 
Pay Ratio 
Number of Employees 
Summary Statistics (n=201) 

Maximum 
$170,756 
$129,499,005 
$256,300 
2508x 
350,600 
90th Percentile 
$19,167 
$15,695,189 
$118,209 
301x 
52,131 
75th Percentile 
$6,946 
$9,989,992 
$86,046 
165x 
17,521 
Median 
$2,138 
$5,422,777 
$61,782 
78x 
5,148 
25th Percentile 
$587 
$2,726,774 
$47,252 
40x 
1,382 
10th Percentile 
$152 
$1,333,951 
$35,724 
20x 
511 
Minimum 
$24 
$306,000 
$4,563 
3x 
19 
Year 1 Early Disclosures:
CEO Pay Ratio 
Revenue ($mm) 
CEO Pay 
Median Employee Pay 
Pay Ratio 
Number of Employees 
Summary Statistics (n=300) 

Maximum 
$213,395 
$113,572,988 
$580,335 
5463x 
364,575 
90th Percentile 
$22,014 
$16,179,146 
$144,886 
325x 
51,370 
75th Percentile 
$7,033 
$10,608,763 
$95,149 
171x 
16,960 
Median 
$1,879 
$5,302,622 
$60,823 
80x 
3,964 
25th Percentile 
$409 
$2,465,703 
$45,349 
32x 
937 
10th Percentile 
$127 
$969,417 
$34,082 
15x 
271 
Minimum 
$0 
$0 
$2,526 
1x 
13 
Location in Proxy Statement
Placement In Proxy 
Prevalence 
Percentage 
Summary Statistics (n=201) 

Before CD&A 
1 
0% 
Within CD&A 
10 
5% 
Directly Before Compensation Tables 
7 
3% 
Within Compensation Tables 
43 
21% 
After Compensation Tables 
140 
70% 
Year 1 Early Disclosures:
Placement In Proxy 
Prevalence 
Percentage 
Summary Statistics (n=300) 

Before CD&A 
1 
0% 
Within CD&A 
14 
5% 
Just Prior To or Within Compensation Tables 
71 
24% 
Following “Potential Payments Upon Termination” Section 
214 
71% 
Supplemental Ratios
Supplemental Ratios 
Prevalence 
Percentage 
Summary Statistics (n=201) 

Companies Disclosing a Supplemental Ratio 
19 
9% 
Companies Not Disclosing a Supplemental Ratio 
182 
91% 
Supplemental Ratios – How Many 
Prevalence 
Percentage 
Summary Statistics (n=19) 

Companies Disclosing One Supplemental Ratio 
18 
95% 
Companies Disclosing More Than One Supplemental Ratio 
1 
5% 
Year 1 Early Disclosures:
Supplemental Ratios 
Prevalence 
Percentage 
Summary Statistics (n=300) 

Companies Disclosing a Supplemental Ratio 
32 
11% 
Companies Not Disclosing a Supplemental Ratio 
268 
89% 
Supplemental Ratios 
Prevalence 
Percentage 
Summary Statistics (n=32) 

Companies Disclosing One Supplemental Ratio 
27 
84% 
Companies Disclosing More Than One Supplemental Ratio 
5 
16% 
Supplemental Ratios – Rationale 
Prevalence 
Percentage 
Summary Statistics (n=19) 

Alternate CEO Compensation Calculation 
12 
63% 
Alternate Employee Compensation Calculation 
2 
11% 
Alternate CEO and Employee Compensation Calculation 
1 
5% 
Alternate Employee Demographic 
2 
11% 
Both Change Compensation Calculation and Employee Demographic 
0 
0% 
Multiple Reasons 
2 
11% 
Supplemental Ratios – Rationale 
Prevalence 
Summary Statistics 

Alternate CEO Compensation Calculation 
13 
Alternate Employee Compensation Calculation 
4 
Alternate CEO and Employee Compensation Calculation 
2 
Alternate Employee Demographic 
3 
Both Change Compensation Calculation and Employee Demographic 
0 
Year 1 Early Disclosures:
Supplemental Ratios – Rationale 
Prevalence 
Percentage 
Summary Statistics (n=32) 

Alternate CEO Compensation Calculation 
17 
53% 
Alternate Employee Compensation Calculation 
1 
3% 
Alternate CEO and Employee Compensation Calculation 
6 
19% 
Alternate Employee Demographic 
4 
13% 
Both Change Compensation Calculation and Employee Demographic 
4 
13% 
Measurement Date / Month
Measurement Date 
Prevalence 
Percentage 
Summary Statistics (n=201) 

Last Day of Q4 
103 
51% 
First Day of Q4 
30 
15% 
Other 
61 
30% 
Not Disclosed 
7 
3% 
Measurement Month 
Prevalence 
Percentage 
Summary Statistics (n=201) 

First Month of Quarter 
54 
27% 
Second Month of Quarter 
17 
8% 
Last Month of Quarter 
123 
61% 
Not Disclosed 
7 
3% 
Year 1 Early Disclosures:


Exemptions From Employee Population
Exemptions From Employee Population 
Prevalence 
Percentage 
Summary Statistics (n=201) 

Disclosed Utilizing Exemptions 
75 
37% 
No Disclosure About Utilizing Exemptions 
126 
63% 
Year 1 Early Disclosures:
Exemptions From Employee Population 
Prevalence 
Percentage 
Summary Statistics (n=300) 

Disclosed Utilizing Exemptions 
106 
35% 
No Disclosure About Utilizing Exemptions 
194 
65% 
Exemptions From Employee Population – Rationale 
Prevalence 
Percentage 
Summary Statistics (n=75) 

Geographic (De Minimis) 
36 
48% 
Do Not Set Group of Employees Pay 
8 
11% 
Merger / Acquisition(s) 
13 
17% 
Employees on Leave of Absence 
3 
4% 
Multiple Reasons 
15 
20% 
Exemptions From Employee Population – Rationale 
Prevalence 
Percentage 
Summary Statistics (n=75) 

Geographic (De Minimis) 
48 
64% 
Do Not Set Group of Employees Pay 
14 
19% 
Merger / Acquisition(s) 
25 
33% 
Employees on Leave of Absence 
4 
5% 
Year 1 Early Disclosures:
Exemptions From Employee Population – Rationale 
Prevalence 
Percentage 
Summary Statistics (n=106) 

Geographic (De Minimis) 
56 
53% 
Do Not Set Group of Employees Pay 
9 
8% 
Merger / Acquisition(s) 
11 
10% 
Multiple Reasons 
21 
20% 
Other 
9 
8% 
Description of Median Employee
Description of Median Employee 
Prevalence 
Percentage 
Summary Statistics (n=201) 

Disclosure Includes A Description of Median Employee 
33 
16% 
Disclosure Does Not Include A Description of Median Employee 
168 
84% 
Type of Description 
Prevalence 
Percentage 
Summary Statistics (n=33) 

Geographic Location of Employment Only 
7 
21% 
Employment Type (Fulltime, parttime, etc.) Only 
0 
0% 
Pay Type (Salary, hourly, etc.) Only 
0 
0% 
Role Only 
4 
12% 
Compensation Detail Only 
2 
6% 
Multiple Descriptors 
20 
61% 
Type of Description 
Prevalence 
Percentage 
Summary Statistics (n=33) 

Geographic Location of Employment 
25 
76% 
Employment Type (Fulltime, parttime, etc.) 
13 
39% 
Pay Type (Salary, hourly, etc.) 
10 
30% 
Role 
16 
48% 
Compensation Detail 
8 
24% 
Year 1 Early Disclosures:
Describes Median Employee 
Prevalence 
Percentage 
Summary Statistics (n=300) 

Disclosure Includes A Description of Median Employee 
35 
12% 
Disclosure Does Not Include A Description of Median Employee 
265 
88% 
Adjustments to Employee Compensation
Cost of Living Adjustments 
Prevalence 
Percentage 
Summary Statistics (n=201) 

Utilized COLA For Median Employee Pay 
1 
0% 
Did Not Utilize COLA For Median Employee Pay 
52 
26% 
Silent 
148 
74% 
Annualized Employee Compensation 
Prevalence 
Percentage 
Summary Statistics (n=201) 

Annualized Employee Compensation per CACM 
84 
42% 
Did Not Annualize Employee Compensation per CACM 
30 
15% 
Silent 
87 
43% 
Year 1 Early Disclosures:
Cost of Living Adjustments 
Prevalence 
Percentage 
Summary Statistics (n=300) 

Utilized COLA For Median Employee Pay 
3 
1% 
Did Not Utilize COLA For Median Employee Pay 
95 
32% 
Silent 
202 
67% 
Annualized Employee Compensation 
Prevalence 
Percentage 
Summary Statistics (n=300) 

Annualized Employee Compensation per CACM 
132 
44% 
Did Not Annualize Employee Compensation per CACM 
40 
13% 
Silent 
128 
43% 
Comparability Disclaimer
Comparability Disclaimer 
Prevalence 
Percentage 
Summary Statistics (n=201) 

Disclosure Includes Disclaimer 
56 
28% 
Disclosure Does Not Include Disclaimer 
145 
72% 
Year 1 Early Disclosures:
Comparability Disclaimer 
Prevalence 
Percentage 
Summary Statistics (n=300) 

Disclosure Includes Disclaimer 
80 
27% 
Disclosure Does Not Include Disclaimer 
220 
73% 
CEO & Median Employee Compensation Includes NonDiscriminatory Benefits
Compensation Includes NonDiscriminatory Benefits? 
Prevalence 
Percentage 
Summary Statistics (n=176) 

Yes 
25 
14% 
No 
151 
86% 
Year 1 Subset of S&P 500:
Compensation Includes NonDiscriminatory Benefits? 
Prevalence 
Percentage 
Summary Statistics (n=353) 

Yes 
45 
13% 
No 
308 
87% 
Joshua Hovden and Stella Kovoros provided research assistance for this report.