Stock Grant Quarterly Approval Policy

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Guidelines for Equitable and Compliant Employee Stock Distribution

This sample policy outlines the procedures for grant approval by senior management and the compensation committee. In this policy, all grants must be approved by senior management and the compensation committee before employees are notified.

The procedures include: in Q1 of the fiscal year, HR (compensation and benefits) sends to requestors (officers and regional HR directors) an email attached with a request form explaining the quarterly grant process; and the requestor prepares the grant request; the requestor obtains email approval (for the number of shares) from the division president, EVPs, chief operating officer, senior vice president human resources, or chief financial officer.

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