Starwood 2015 Annual Report Download - page 33

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Table of Contents
• Internal Processes Further Restrict Risk: We have in place additional processes to limit risk to us from our compensation programs. Specifically, we have
financial policies that restrict the amount of capital that any individual may deploy absent obtaining internal approvals, which reduce the risk of inappropriate
expenditures by an individual. Further, the processes and controls associated with respect to our compensation programs are audited each year to ensure that
expenditures have been approved within our guidelines and by required approval authorities. In addition, we engage an external compensation consulting firm
for design and review of our compensation programs, as well as external legal counsel to assist us with the periodic review of our compensation plans to ensure
compliance with applicable laws and regulations.
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