Each year the criteria evolve and address more issues as the needs of the investor community grow, but the mission of these awards remains the same: Transparency creates confidence and therefore value for companies and their stakeholders.

The Transparency Awards are organized by Labrador, a regulated communication consultancy firm.

The complete list of transparency criteria

Proxy Statement

01 | The document is available in print PDF format

02 | The document is available in an interactive format on the Investor Relations web page

03 | The print version of the document uses a two-column page layout

04 | The SEC EDGAR version of the document uses a one-column page layout

05 | The top of each page in the print version indicates the relevant section and subsection

06 | Every page footer includes the company name, document title, and year

07 | The document includes a secondary color

08 | The second page of the document is either the table of contents, company overview, or values statement

09 | Voting and general information is presented at the back of the proxy

10 | There is a proxy summary containing compensation and governance highlights

11 | The proxy summary includes a table summarizing the proposals and the board’s recommendation for each one

12 | The CD&A starts with a dedicated table of contents

13 | At a minimum, the CD&A Executive Summary includes a table of the NEOs and provides business highlights

14 | The proxy summary includes a strategy or company overview

15 | A shareholder engagement graphic appears somewhere in the document

16 | The document includes a summary of key governance practices and policies (what we do / don’t do, or list)

17 | The company provides a QR code to access voting options and information about the annual meeting

18 | The company explains how shareholders can submit questions for the annual meeting

19 | The cover includes the time and date of the annual meeting

20 | The Notice of annual meeting includes voting icons (mail, phone, internet)

21 | The letter from the Chairman or CEO (or combined role) includes company or governance highlights rather than just meeting information

22 | There is a letter from the entire Board of Directors

23 | At least 30% of the Board members are women

24 | Each director biography includes a photo

25 | Within each director biography, at least three items (such as tenure, age, and committee assignment(s)) are called out separately

26 | The company discusses its position on diversity beyond the board level (recruiting employees)

27 | The company discusses at what level its ESG initiatives are overseen (management, board, specific board committee)

28 | Committee descriptions include the aggregate meeting attendance rate

29 | The attendance rate disclosed for the entire board is precise rather than the minimum “more than 75%” requirement

30 | Each committee description includes a summary of the topics discussed during the year

31 | Key governance changes or the Board’s areas of focus are clearly outlined

32 | The board evaluation section discusses the results and, if warranted, the proposed enhancements or actions taken

33 | The document discusses the implementation or monitoring of (or responsibility for) a succession plan

34 | The document discusses director onboarding or continuing education

35 | The document includes a link directly to the code of conduct

36 | The company explains its approach to cybersecurity

37 | The letter from the Compensation Committee includes highlights about the compensation program

38 | The document includes a summary of key compensation practices and policies (what we do / what we don’t do, or list)

39 | The CD&A includes a discussion of each individual NEO’s role, performance, and total compensation

40 | The company discloses whether it has a clawback provision for executive compensation

41 | The document discusses human capital management in the ESG/CSR section

42 | Reference to a sustainability framework or the UN Sustainable Development Goals

43 | The company explains why each particular skill is relevant to the company

44 | The company discloses the criteria used to identify the companies in the peer group and shows how the company fits into the peer group with respect to those criteria

45 | The company mentions the prior years’ Say on Pay score within the CD&A

46 | The company uses diversity, environmental, or other ESG-focused metrics in the annual incentive program

47 | The company explains (i) whether it follows a “Rooney Rule,” (ii) whether the rule is a firm policy (in a committee charter or separate document adopted by the Board) or just a commitment, and (iii) which roles (Board, CEO, other executives) the rule applies to

48 | There is an individualized Board matrix that provides diversity information—either alone or combined with skills information

49 | The components of director compensation (including all retainers and equity awards) are disclosed in a table or other easily understood graphic

50 | The CD&A includes a table or other graphic showing the current payout percentages (based on performance to date) for outstanding equity awards

51 | At a minimum, the proxy includes a graphic summary of directors’ ages and tenures

52 | The document includes a director skills matrix

53 | The document includes a separate board committee matrix or discloses committee memberships within a board nominee table in the proxy summary

54 | The document includes a graphic showing the board evaluation process

55 | The document has a CSR or ESG section containing graphics or key figures that describe ESG highlights (diversity, gender parity, carbon emissions, etc.)

56 | Within the director compensation section, a graphic is included to show allocation of various direct compensation elements

57 | A section on business performance highlights (in the CD&A or the proxy summary) incorporates at least two graphics

58 | The CD&A contains at least three graphics depicting compensation of the NEOs

59 | A table or graphic is used to present the target and final results of the short-term incentive plan

60 | A table or graphic is used to present the final results of the long-term incentive plan for the performance that just ended

61 | The document includes a shareholder engagement section

62 | The document includes “human capital management” information

63 | Within the shareholder engagement section, the company includes who from the company participated and how many shareholders were contacted and topics discussed

64 | The document includes a graphic showing stock ownership by each Named Executive Officer compared to ownership guidelines, if any

65 | The distribution of specific risk oversight responsibilities among the Board, Board committees, and management is depicted in a graphic.

66 | There were at least 45 days between the filing and the annual meeting

Form 10-K

67 | The Investor Relations website offers an interactive version of the Annual Report

68 | There is a table of contents on page 2 with two levels (sections and subsections) of detail

69 | The document is available in PDF print format (not a PDF of the HTML)

70 | The top of each page in the print version indicates the relevant section and subsection

71 | Every page footer includes the company name, document title, and year

72 | The document uses a two-column page layout

73 | Item 1 – Business contains an overview of the company’s strategy

74 | The document contains a glossary of terms or key word index

75 | The document includes a secondary color

76 | Item 1 – Business contains a graphic to highlight the company strategy

77 | The tables throughout the MD&A have titles

78 | The Notes to Consolidated Financial Statements have a dedicated table of contents

79 | Within Item 1, the document provides a direct link to the website hosting all of the company’s SEC filings

80 | The “Risk Factors” section begins with a summary of major risks

81 | The “Risk Factors” section is broken into subsections by the type of risk

82 | The company identifies cybersecurity is a major risk

83 | The segments in the Business Overview are an exact match to the segments discussed in the MD&A

84 | The company identifies environmental issues as a risk

85 | Within the human capital management section there is a subsection on employee recruitment and training

86 | The company discloses global workforce statistics on gender

87 | The company discloses workforce statistics on race

88 | Within the human capital management section there is a subsection on employee health and safety

89 | Within the human capital management section there is a subsection on culture and engagement

90 | Within the human capital management section there is a subsection on diversity and inclusion

91 | The MD&A contains at least one graphic to highlight company performance

92 | The document follows a logical structure recommended by the SEC

93 | Each section of the report is labeled with the appropriate name from the regulations (i.e., “Risk Factors,” “Management Discussion and Analysis,” etc.)

94 | There were no more than 50 days between the filing and the fiscal year-end

Investor Relations Website

95 | The homepage of the corporate website includes “Investors” or “Investor Relations” with other prominent level one headings

96 | The Investor Relations search engine is quick and accurate

97 | The IR home page has a menu offering direct access to sub-sections

98 | There is a Sustainability or Corporate Responsibility section clearly identified and accessible from the IR homepage

99 | There is an “Annual Meeting” sub-section that includes access to the 10-K, Proxy Statement and a link to voting

100 | The “contact” page offers an option to send an email to investor relations or a specific contact in Investor Relations

101 | Readers can access the 10-K or Proxy from the IR home page in two (or fewer) clicks

102 | The IR site offers easy and public access to the annual meeting webcast or transcript

103 | The IR site offers an option to register for email alerts

104 | A search for “Company 2021 Annual Report” on any search engine will lead to the current Annual Report in the top five results

105 | A search for “Company 2022 Proxy Statement” on any search engine will lead to the current Proxy Statement in the top five results

106 | There is an “Annual Report and Proxy Statement” subsection that includes a link to PDF versions of the Annual Report or 10-K and Proxy Statement

107 | Readers can access the Proxy from the IR home page in two (or fewer) clicks

108 | The company website’s search engine provides easy access to information related to “ethics,” “strategy,” and “sustainability”

109 | Readers should be able to view the company’s latest earnings presentations

110 | Readers can access the Code of Ethics or Code of Business Conduct from the IR home page in two (or fewer) clicks

111 | The company’s website has a dedicated Ethics and Compliance tab

112 | Readers have access to the last five Annual Reports

113 | The company’s current bylaws are posted and easily accessed

114 | A subsection within the Investor page is called “SEC Filings”

115 | A subsection within the Investor home page is called “Corporate Governance” or “Governance”

116 | The home page of the IR site includes, at a minimum, “Events and Presentations,” “Stock Information,” and “contact or FAQ”

117 | There is a dedicated website or landing page for the Annual Meeting that includes all materials needed for the AGM

Code of conduct

118 | The document is available to the public on the company’s investor relations or corporate website

119 | The document is available in print PDF format

120 | The document is available in an interactive format, sending the reader to additional content such as a video or intranet for more information

121 | A search for “code of ethics or code of conduct Company name” in any search engine will lead to the most recent document in the top three results

122 | The document is titled either Code of Ethics or Code of (Business) Conduct

123 | The document uses personal pronouns (we, you) rather than titles (the Company, every employee)

124 | The document is translated into three or more languages, not including English

125 | If the document is translated, the translated documents are available on the same landing page as the English version on the corporate website

126 | The document includes a table of contents

127 | The document includes a graphic depicting the reporting procedure

128 | The document includes direct link(s) to other policy(ies)

129 | The company values are presented at the beginning of the document

130 | The document is dated and produced or updated within the last two years

131 | The Code includes a chapter or paragraph about code violations

132 | The section on reporting violations includes at least three ways (phone, email, physical address) to anonymously report a concern

133 | A letter from the CEO and/or the CCO introduces the Code

134 | The Code mentions a training program

135 | Comprehensiveness: at least seven themes included

136 | The company indicates the response time if an incident is reported to the hotline

137 | The company presents the governance structure of the ethics and compliance program

138 | The document says the company has a policy that prohibits retaliation against people who report concerns

139 | The letter mentions (i) the importance of ethics, compliance and integrity, (ii) following the code, and (iii) reporting a concern

140 | The document contains a minimum of three graphics or infographics

141 | The document includes a decision-making tree graphic

142 | The document includes at least three practical case studies or examples (Q&A)

143 | The table of contents is organized by stakeholder group (Employees, Customers & Suppliers, The Company, Community/Society)

144 | A list of the different code(s) or policy(ies) are available on the same landing page as the Code

145 | The document includes a section about the Code’s purpose and who it applies to

146 | The document refers to other policy(ies)

PLAIN LANGUAGE

1 | Average sentence length is 20 words or less

2 | 98% sentences or more in active form

3 | 98% sentences or more in affirmative form

4 | 20% or less complex sentences

5 | 15% or less sentences with parenthesis

6 | 7% or less adjectives

7 | 2% or less adverbs

8 | 0.5% or less Latin or foreign words

9 | 0.5% or less elaborate or old words

10 | No more than 80 words in paragraphs

11 | No more than 4 paragraphs on average between intermediate titles

12 | Max 20 words per sentence for bullet points