April 10, 2019

CAPintel

A Deep Dive into the Second Year of CEO Pay Ratio Disclosures

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 company-by-company 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:

  1. CEO Pay Ratio: While CEO pay ratio summary statistics (e.g., 25th percentile, median, and 75th percentile) were flat across the sample, two-thirds 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 year-over-year.
  2. CEO Pay: CEO compensation increased 7 percent at median with two-thirds 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.
  3. Median Employee: Only 36 percent of companies used the same median employee year-over-year. 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 year-over-year 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.
  4. 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, full-time vs. part-time, 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 prior-year 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 company-matched basis, the percentage change of pay ratio was flat at median (-1%), 25th percentile (+1%) and 75th percentile (0%). Despite the flat year-over-year 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 company-matched 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 two-thirds of companies had year-over-year changes in the pay ratio of more than +/-10 percent. This shows that while the total sample may seem unchanged year-over-year, 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 year-over-year with two-thirds of CEO pay fluctuating by more than 10 percent compared to one-third 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 re-selecting 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 re-selecting 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 re-running 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 prior-year 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 pay-ratio 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 non-discriminatory 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 non-discriminatory benefits in the calculation this year, compared with approximately 13 percent of the S&P 500 last year. Including these non-discriminatory 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 year-over-year, 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 one-time 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 non-U.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 early-filer 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 (full-time versus part-time) 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 non-U.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 non-U.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 company-matched 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:

Measurement Date

 

Prevalence

 

Percentage

Summary Statistics (n=300)

Last Day of Q4

141

47%

First Day of Q4

50

17%

Other

94

31%

Not Disclosed

15

5%

Measurement Month

 

Prevalence

 

Percentage

Summary Statistics (n=300)

First Month of Q4

86

29%

Second Month of Q4

23

8%

Last Month of Q4

176

59%

Not Disclosed

15

5%

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 (Full-time, part-time, 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 (Full-time, part-time, 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 Non-Discriminatory Benefits

Compensation Includes Non-Discriminatory Benefits?

 

Prevalence

 

Percentage

Summary Statistics (n=176)

Yes

25

14%

No

151

86%

Year 1 Subset of S&P 500:

Compensation Includes Non-Discriminatory Benefits?

 

Prevalence

 

Percentage

Summary Statistics (n=353)

Yes

45

13%

No

308

87%

Joshua Hovden and Stella Kovoros provided research assistance for this report.