July 21, 2009
If shareholder vote on executive compensation is approved, additional disclosure should be added to the compensation discussion and analysis. To allow shareholders to make informed voting decisions, the compensation discussion and analysis should discuss key financial and risk decisions that the executive made during the compensation year and how they arrived at those decisions. The discussion should also address how these decisions may impact the company in both the short term and potentially in the long term. For example they may approve a new union contract that may be beneficial to the company in the short term, but may include unrealistic future pay and benefit increases that could prove to be detrimental to the company.