A Standard Document establishing a clawback policy that is intended to meet the requirements of Section 954 of the Dodd-Frank Act. This Standard Document contains integrated notes with important explanations and drafting tips. This Standard Document reflects the final rules issued by the SEC on October 26, 2022 and the implementing listing standards proposed by the NYSE and Nasdaq stock exchanges on February 22, 2023, amended by the NYSE and Nasdaq stock exchanges on June 5, 2023, and approved by the SEC on June 9, 2023. The listing standards became effective on October 2, 2023. Listed companies are required to adopt a Dodd-Frank compliant clawback policy by December 1, 2023.