The U.S. Securities and Exchange Commission has proposed pay ratio disclosure rules that would require public companies to disclose the median of the annual total compensation of all employees, other than the chief executive officer; the annual total compensation of the chief executive officer; and the ratio of these amounts. The proposed disclosure covers all employees of the company and its subsidiaries as of the last day of the prior fiscal year, including employees based outside of the United States, part-time employees, temporary employees and seasonal employees. The proposing release contemplates a transition period so that the initial pay ratio disclosure would be required with respect to compensation for a company’s first full fiscal year that begins after the final rules are adopted.
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