November 29, 2013
I am writing in strong support of the SEC's CEO-Median Employee Pay Ratio Rule as drafted.
Others, such as Adam Kanzer, Managing Director and General Counsel of Domini Social Investments LLC, have provided excellent feedback on the specific measures provided in this rule.
I wish to reinforce his comments regarding how this rule should better align the interests of the individual CEOs of public corporations with the interests of their firm's stakeholders -- investors, employees, and related groups -- who comprise the corporation's supporting public.
The ratio as constructed in the rule, when added to other critical indicators of corporate policy, will improve the data available to analyze corporate strategy with respect to employee compensation and turnover, increasingly important concerns as human capital is predicted to be scarcer in the future.