Berkshire Hathaway Inc.

3/17/23

7/28/23

X

X

Expeditors International of Washington, Inc.

3/21/23

7/28/23

X

X

Xylem Inc.

4/3/23

7/28/23

X

X

Americold Realty Trust, Inc.

4/6/23

8/4/23

X

X

X

TTEC Holdings, Inc.

4/11/23

8/25/23

X

X

X

Pediatrix Medical Group, Inc.

3/31/23

7/27/23

X

Healthcare Services Group, Inc.

4/28/23

8/9/23

X

X

X

Equitrans Midstream Corporation

2/23/23

8/4/23

X

Tootsie Roll Industries, Inc.

3/23/23

7/27/23

X

X

X

Argan, Inc.

5/1/23

8/9/23

X

X

Corcept Therapeutics Incorporated

4/14/23

8/7/23

X

X

X

Artivion, Inc.

4/3/23

8/4/23

X

X

X

QCR Holdings, Inc.

4/4/23

7/27/23

X

X

NexPoint Residential Trust, Inc.

4/11/23

7/28/23

X

X

X

Harvard Bioscience, Inc.

4/5/23

7/28/23

X

Tenax Therapeutics, Inc.

4/28/23

8/7/23

X

X

Totals

–

–

11

9

6

4

2

4

Berkshire Hathaway Inc.

• Identify the PEO and each NEO included in the table, and the years in which such persons are included
• Provide description of relationship between CAP and financial performance

Expeditors International of Washington, Inc.

• If describing requirements of SEC Pay vs. Performance, do so correctly (company labeled SCT values as CAP, and called CAP “Absolute Pay”)
• Use the correct terminology and measures in the relationship charts
• Provide description of relationship between CAP and Net Income

Xylem Inc.

• Clarify footnote of reconciliation table. Equity awards granted in prior years that vest during the year should be valued as the difference between the fair value as of the prior fiscal year and the vesting date, not the “year over year” change
• Include CSM in the tabular list of most important financial performance measures

Americold Realty Trust, Inc.

• Provide description of relationship between CAP and Net Income (company only provided charts for CAP vs. TSR and CAP vs. CSM)
• Since CSM is non-GAAP, provide disclosure of how this number is calculated
• Provide tabular list of 3-7 most important financial performance measures

TTEC Holdings, Inc.

• Identify each NEO included in the table for every year presented
• Ensure fair values of equity awards granted in the covered fiscal year are calculated correctly
• Provide descriptions of relationship between CAP and financial performance (currently incomplete)
• Only include one CSM (company included three CSMs)
• For non-GAAP metrics, provide disclosure of how those metrics are calculated

Pediatrix Medical Group, Inc.

• Include GAAP Net Income (company included income from continuing operations instead of net income)

Healthcare Services Group, Inc.

• Ensure all compensation paid to NEOs is included in the table
• Provide description of relationship between TSR and peer group TSR
• TSR peer group needs to match what is used for Reg. S-K or compensation peer group (TSR peer group was not the same as the index used for disclosures and that index was based on financial characteristics)
• Peer group must be disclosed in a footnote if it is not a published industry or index

Equitrans Midstream Corporation

• If describing requirements of SEC Pay vs. Performance, do so correctly
• Revise table of reconciliation of adjustments to clearly indicate when equity awards were granted (current or prior year) and the time period over which changes in value are measured

Tootsie Roll Industries, Inc.

• Provide description of relationship between CAP and financial performance
• Ensure tabular list of measures includes at least three but no more than seven financial performance measures
• Include separate columns in the table for the PEO’s total compensation and the average compensation for the non-PEO NEOs

Argan, Inc.

• Revise table of reconciliation of adjustments to totals to show each numerical amount added and deducted (company combined both vested and unvested stock awards into one amount)
• Since CSM is non-GAAP, provide disclosure of how this number is calculated

Corcept Therapeutics Incorporated

• If describing requirements of SEC Pay vs. Performance, do so correctly
• Provide description of relationship between CAP and financial performance
• TSR peer group needs to match what is used for Reg. S-K or compensation peer group (company used broad-based index that didn’t match Reg. S-K disclosure)

Artivion, Inc.

• Clarify footnote in reconciliation table. Equity awards granted in prior years that vest during the year should be valued as the difference between the fair value as of the prior fiscal year and the vesting date, not the “year over year” change
• Ensure table headings accurately reflect the amounts used to calculate CAP
• Provide description of relationship between CAP and Net Income, and CSM. It is not sufficient to state that no relationship exists
• Ensure clear description of how CSM is calculated, and ensure it is calculated in the same way for each year in the table

QCR Holdings, Inc.

• Disclose each numerical amount under Reg. S-K in the reconciliation table and calculate “Pension Benefit Adjustments”
• Since CSM is non-GAAP, provide disclosure of how this number is calculated

NexPoint Residential Trust, Inc.

• Provide CSM, tabular disclosure and relationships of any financial performance measure used to link CAP to performance (company has footnote to PBA that suggests awards are granted based on factors that influence the Company’s stock, but did not include a CSM)

Harvard Bioscience, Inc.

• Correct the SCT amounts in pay versus performance tables

Tenax Therapeutics, Inc.

• Clarify footnote in reconciliation table. Equity awards granted in prior years that vest during the year should be valued as the difference between the fair value as of the prior fiscal year and the vesting date, not the “year over year” change
• Include all NEOs in the average calculations for NEOs (company only disclosed SCT total and CAP for one NEO when multiple served in each year)