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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.