List of companies identified under Director Performance and Pay for Performance Policies

2009 Performance Tests

Companies identified under Director Performance and Pay for Performance Policies

The lists below identify Russell 3000 companies that performed below the median of their respective GICS peer groups on both one-year and three-year total shareholder return as of the respective dates. Companies on this list will not necessarily receive withhold/against recommendations on their directors. Rather, this list serves as an initial performance screen that will identify underperforming companies for purposes of evaluating director performance in uncontested elections and CEO pay relative to company performance. If a company is identified on this list, RiskMetrics will apply a case-by-case approach taking into account numerous factors as it relates to these two policies, which can be found on p. 16 and pp. 33-35 of the 2009 RiskMetrics U.S. Proxy Voting Summary Guidelines. This list will also identify companies that do not meet the performance standard when applying the performance component in our policy for shareholder proposals seeking an independent chair (found on pp. 14-15 of the summary guidelines).

All companies’ stock performance will be measured as of Dec. 31, March 30, June 30, and Sept. 30 and the corresponding lists will be generated as of these dates. RMG will display the two most up-to-date lists on a quarterly basis. Given that executive compensation is reported on a fiscal year basis and that fiscal year ends vary by company, the applicable list to check will depend on where a company’s fiscal year falls within a specified range.

Companies should refer to the list appropriate to their fiscal year ending date: