Track 1: Interactive Benchmarking Series — Working Through Complex Risk and Compliance Issues Posed by the Compensation Incentives and Clawbacks Pilot Program: Concrete Examples of Program and Policy Changes

November 29, 2023 5:05pm

Una Dean
VP, Assistant General Counsel, Head of Global Investigations
IBM

Shana Cappell
Senior Director, Chief Anticorruption/Investigations Counsel
PepsiCo, Inc.

Greg D. Andres

Greg Andres
Partner
Davis Polk & Wardwell LLP

Kimberly A. Parker
Partner
WilmerHale LLP

Sarah Walters
Partner
McDermott Will & Emery

  • Revisions to the Evaluation of Corporate Compliance Programs (ECCP)
  • How organizations have been revisiting their compensation programs
  • Challenges to implementation in foreign jurisdictions, including local employment laws
  • Determining what an overall “good-faith effort” on the part of companies really means
  • Developing the structure and scope of a written clawback policy — and carefully considering who the policy is going to cover:
    • officers only?
    • senior employees above a certain level?
    • all supervisory employees?
    • all sales employees?