Resources / Organizations
Organizations / Executive Separations

Separating a Senior Executive: The Employer's Checklist

An executive departure touches contracts, equity, disclosure, and reputation at once. The companies that handle it well plan it before anyone is in the room.

The short answer

Before an executive separation, review every agreement that governs it, check the record for protected activity and consistent treatment, confirm who must approve, and plan the announcement and transition. Offer a separation agreement that meets release requirements, including OWBPA timing for executives 40 and older, and have tax and securities counsel review deferred compensation, clawback, and disclosure obligations.

1. Read everything that governs the exit

  • The employment agreement or offer letter, especially "cause," "good reason," notice periods, and severance formulas.
  • Any executive severance plan or change-in-control agreement.
  • Equity plans and each grant: vesting, acceleration, and exercise windows.
  • Bonus and deferred compensation plans.
  • Restrictive covenants, which vary widely by state and are unenforceable in some.
  • Indemnification agreements and D&O coverage for the executive's time in office.

2. Check the record before you decide

  • Protected activity: Has the executive raised concerns about discrimination, harassment, safety, fraud, or securities violations, taken protected leave, or requested an accommodation? Timing near protected activity is the most common basis for a retaliation claim.
  • Consistent treatment: How were comparable executives handled? Differences need a documented business reason.
  • Documentation: Does the record support the stated reason? A sudden cause termination after years of strong reviews invites a pretext argument.

3. Confirm authority and approvals

Know whether the board, a committee, or the CEO must approve the termination and the separation terms. Compensation committee approval is often required for officer severance and equity changes. Process lapses can undermine an otherwise sound decision.

4. Build a separation agreement that holds

  • A release in exchange for consideration beyond what the executive is already owed.
  • For executives 40 and older releasing age claims: written advice to consult an attorney, at least 21 days to consider (45 in a group program with required disclosures), and 7 days to revoke.
  • Carve-outs required by law, including the right to file an EEOC charge and to communicate with the SEC.
  • Payment timing that fits Section 409A. Public companies may need to delay some payments to "specified employees" by six months. Have a tax advisor review.
  • Cooperation, transition, non-disparagement, and return-of-property terms.

5. Public companies: clawback and disclosure

Listed companies must maintain a clawback policy under SEC Rule 10D-1 that recovers erroneously awarded incentive compensation after an accounting restatement. Separation terms should not conflict with it. The departure of certain officers, such as the principal executive, financial, and operating officers, generally requires a Form 8-K under Item 5.02 within four business days, and material separation agreements may need to be filed.

6. Plan the conversation, the message, and the handover

  • Script the meeting: who is present, what is said, what is handed over, and what happens next.
  • Agree the internal and external announcement and who is told first: board, leadership team, key clients, investors.
  • Plan the transition of responsibilities, relationships, and signing authority.
  • Coordinate system access, devices, and company property on the day.

For the executive's side of the same process, see how executives negotiate severance.

"An executive exit is judged three ways: by the people who stay, by the market, and later, possibly, by a jury. Plan for all three."

Noël Tarquinii, SHRM-SCP
Key data points
21 / 45 / 7

Days to consider, days in a group program, and days to revoke an age-claim release.

29 U.S.C. 626(f)
4 business days

To file a Form 8-K when a public company's principal officers depart.

SEC Form 8-K, Item 5.02
47.8%

Of FY2024 EEOC charges alleged retaliation, the most common basis for 17 straight years.

EEOC FY2024 enforcement statistics

Common questions

Do we have to offer severance to a departing executive?

Only if an agreement, plan, or policy requires it. In practice, most companies offer consideration in exchange for a release of claims and a clean transition.

Can a separation agreement stop an executive from going to the EEOC or SEC?

No. A release can waive the right to recover money in many cases, but it cannot bar filing an EEOC charge or communicating with the SEC, and the agreement should say so.

How long must we give an executive to sign?

For executives 40 and older releasing age claims, at least 21 days (45 in a group program) plus 7 days to revoke. For others, a reasonable review period is standard practice.

Should we terminate for cause?

Only if the facts clearly meet the contract's definition of cause and the record supports it. A contested cause termination often costs more than the severance it was meant to avoid.

What does a public company have to disclose?

The departure of principal officers generally requires a Form 8-K under Item 5.02 within four business days, and material agreements may need to be filed. Securities counsel should confirm.

When to bring in counsel

Involve employment counsel before the decision is communicated, a tax advisor for equity and deferred compensation, and securities counsel for public-company disclosure and clawback questions. Workplace Intelligence advises on process, risk, and transition planning; it does not provide legal advice.

For employers

Find the exposure before a claim does.

The Organizational Risk Diagnostic reviews your documentation, complaint handling, investigations, and terminations, and delivers a written report in 10 business days. From $15,000, fully credited toward a build or advisory engagement within 30 days.