Leadership
Mandatory or Discretionary? How Boards Should Separate the Two Kinds of Executive Clawback Policies
Boards must manage two distinct executive clawback policies: a mandatory, SEC Rule 10D-1 compliant policy for financial restatements, and a separate, discretionary policy tailored to address broader risks like misconduct and reputational harm.
Simone Devereaux·November 10, 2026
