GC Comp Trends from Law.com Report

Law.com analyzed the top 526 GC pay from Fortune 1000 companies’ proxy statements covering fiscal year ending after June 30, 2023. (Note: this is “an imperfect snapshot of the pay landscape” because companies disclose pay for only their top 5 most highly paid execs, so GC/CLO data is missing from Microsoft, Meta, and Tesla.)?

The highlights:

• Average GC/CLO pay rose from $3.52M in 2022 to $3.62M in 2023. Median pay also rose (albeit minimally) from $2.69M in 2022 to $2.72M in 2023.?
• Tech companies pay the most overall; their GC/CLOs make up 6 of the top 10. At #1 in 2023, Alphabet’s Kent Walker made $27.3M in total. #2 was Apple’s Kate Adams at $26.9M.
• For tech companies, the bulk of GC/CLO comp comes from stock that vests over time. “While in proxy statements it’s valued at the time of grant, the actual value they’ll reap could be substantially more or substantially less. That means what the $24.3 million in stock grants that Walker received in 2023 will be worth when he is eligible to cash in will depend partly on how successful he is containing a labyrinth of threats, from the antitrust litigation to compliance with the European Union’s new Digital Markets Act.”
• The highest base salary on the list was Netflix’s David Hyman at $4M, 29% of his total comp of $13.7M. Note, however, Netflix implemented a new comp plan that caps Hyman’s salary at $1.5M for 2024.
• Amazon’s philosophy of periodic stock grants, “a vague timetable that leaves some years without any,” resulted in a big drop in comp for David Zapolsky from 2022 to 2023. In 2022, he? made $18.2M, #7 in the top 10 comp. “But in 2023, he earned just $371,600, dropping him to 526th— making him the lowest-paid legal chief in the entire survey.”