Companies that are listed on the Nasdaq Stock Market or the New York Stock Exchange are required to adopt a clawback policy that provides for the recovery from any current or former executive officers of incentive-based compensation in excess of the amount that would have been paid based on an accounting restatement. The Nasdaq and NYSE listing rules require listed companies to (i) adopt a compliant clawback policy by December 1, 2023, (ii) apply their clawback policies to all incentive-based compensation received on or after October 2, 2023, the listing rules’ effective date (Effective Date), and (iii) comply with new disclosure requirements for annual reports and proxy statements beginning December 1, 2023.