The Dodd-Frank Wall Street Reform and Consumer Protection Act, commonly referred to as “Dodd Frank”, was signed into U.S. federal law by President Barack Obama in 2010 and represents significant changes to financial regulation in the United States. As a Canadian-based Foreign Private Issuer under securities regulations in the United States, we are not required to comply with the disclosure requirements of the Dodd-Frank Wall Street Reform and Consumer Protection Act; however, we choose to disclose the annual total compensation of the highest-paid individual – our CEO – to the median annual total compensation for employees because we believe that transparency matters. G4-53
We communicate the compensation of our Board of Directors and our five highest paid executive officers on an individual level via our annual Proxy Statement and Information Circular. We also publicly disclose what performance measures are relevant for performance based variable compensation. As a publicly traded company, we believe our stakeholders have a right to know this information, and we believe this level of disclosure strengthens trust in Vermilion.
Although not required, we take our disclosure practices a step further and also disclose the annual total compensation (includes base salary, bonus, Vermilion Incentive Plan and allowances) of the highest-paid individual – our CEO – to the median annual total compensation for employees in the Performance Metrics Table of our Sustainability Report. G4-54
Vermilion’s 2015 CEO-to-average worker ratio of 26.8 to 1 is significantly lower than the 2015 CEO-to-worker pay ratio for S&P 500 Index companies of 335 to 1, as reported by the American Federation of Labor-Congress of Industrial Organizations.