6 TH EDITION | GUIDE TO EFFECTIVE PROXIES 386 2.17.6 CEO to median employee pay ratio Internal pay equity has been a topic of great interest to many stakeholder groups, including company employees, for years. Also, investors have been able to calculate the ratio between CEO and NEO pay from traditional proxy disclosures. On August 5, 2015, the SEC approved final rules implementing the Dodd-Frank requirement that companies calculate and disclose the ratio between CEO and median employee pay. For most companies, these final rules came into effect in time to cover 2017 pay, and (except for a relatively few “early adopters”) their first Pay Ratio disclosure appeared in their 2018 proxy statements. Now that companies, investors and others have seen most company ratios and qualitative discussion including how companies compare to peers, it will be interesting to see how investors and others incorporate this information into their engagement discussions and proxy voting.