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
Una Dean
VP, Assistant General Counsel, Head of Global Investigations
IBM
Shana Cappell
Senior Director, Chief Anticorruption/Investigations Counsel
PepsiCo, Inc.
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?