Exhibit 97.1
CLAWBACK POLICY
(Effective November 30, 2023)
If Smith & Wesson Brands, Inc. (together with its subsidiaries, the “Company”) is required to prepare an Accounting Restatement (as defined below), then the Company will recover reasonably promptly the amount of Erroneously Awarded Compensation (as defined below) Received by any current or former Executive Officer (as defined below) during the Recovery Period (as defined below).
The Company will not be required to enforce this policy if the Compensation Committee determines that (i) recovery would be impracticable as determined by the Company’s Compensation Committee and (ii) one of the conditions of (A), (B), or (C) are satisfied:
The Company is prohibited from indemnifying any current or former Executive Officer against the loss of any Erroneously Awarded Compensation or paying or reimbursing such Executive Officers for insurance premiums to recover losses incurred under this policy.
This policy is intended to comply with Nasdaq Listing Rule 5608, as required by Section 10D of the Securities Exchange Act of 1934, as amended (Exchange Act) and Rule 10D-1 promulgated thereunder. The Compensation Committee shall have express discretionary authority to interpret and administer this policy and to make all determinations with respect to this policy in its sole discretion which shall be final and binding on all parties.
Definitions: For purposes of this policy: