Symantec 2016 Annual Report Download - page 66

As of July 1, 2016, each of our named executive officers has reached the stated ownership requirements for
fiscal 2016. See the table below for individual ownership levels relative to the executive’s ownership require-
ment.
Named Executive Officer
Ownership
Requirement(1)
(# of shares)
Holdings as of
July 1, 2016
Michael A. Brown ........................................... 244,379 209,971
Thomas J. Seifert ............................................ 105,572 41,374
Balaji Yelamanchili .......................................... 68,426 114,096
Scott C. Taylor .............................................. 58,651 161,622
Francis C. Rosch ............................................ 51,320 95,132
(1) Based on the closing price for a share of our common stock of $20.46 on July 1, 2016.
Recoupment Policies (Clawbacks)
Since fiscal 2009, we have included provisions within our executive annual incentive plans to the effect that
we will seek reimbursement of excess incentive cash compensation if our financial statements are the subject of a
restatement due to error or misconduct.
Insider Trading, Hedging and Pledging Policies
Our Insider Trading Policy prohibits all directors and employees from short-selling Symantec stock or
engaging in transactions involving Symantec-based derivative securities, including, but not limited to, trading in
Symantec-based option contracts (for example, buying and/or writing puts and calls). It also prohibits pledging
Symantec stock as collateral for a loan.
In addition, our Insider Trading Policy prohibits our directors, officers, employees and contractors from
purchasing or selling Symantec securities while in possession of material, non-public information. It also requires
that each of our directors, our Chief Executive Officer and our Chief Financial Officer conduct open market sales
of our securities only through use of stock trading plans adopted pursuant to Rule 10b5-1 of the Exchange Act.
Rule 10b5-1 allows insiders to sell and diversify their holdings in our stock over a designated period by adopting
pre-arranged stock trading plans at a time when they are not aware of material nonpublic information about us,
and thereafter sell shares of our common stock in accordance with the terms of their stock trading plans without
regard to whether or not they are in possession of material nonpublic information about the Company at the time
of the sale. All other executives are strongly encouraged to trade using 10b5-1 plans.
Tax and Accounting Considerations on Compensation
The financial reporting and income tax consequences to the Company of individual compensation elements
are important considerations for the Compensation Committee when it reviews compensation practices and
makes compensation decisions. While structuring compensation programs that result in more favorable tax and
financial reporting treatment is a general principle, the Compensation Committee balances these goals with other
business needs that may be inconsistent with obtaining the most favorable tax and accounting treatment for each
component of its compensation.
Deductibility by Symantec. Under Section 162(m) of the Code, we may not receive a federal income tax
deduction for compensation that is not performance-based (as defined in the Section 162(m) rules) paid to the
Chief Executive Officer and the next three most highly compensated executive officers (other than our Chief
Financial Officer) to the extent that any of these persons receives more than $1,000,000 in nonperformance-based
compensation in any one year. However, we strive to maximize the tax deductibility of our compensation awards
since our philosophy is to provide the largest proportion of compensation as performance-based. While the
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