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Heidy Chow

Chief Financial Officer at Snail
Executive
Board

About Heidy Chow

Heidy K. Chow is Chief Financial Officer (since September 2020), Secretary, and a Director of Snail, Inc. (SNAL). She is a licensed CPA, holds a B.S. from California Polytechnic University, Pomona, and previously worked at EY and as a partner at The Pun Group LLP . She is 46 and has served on SNAL’s board since January 11, 2022; she also serves on the board of Snail Games USA, Inc. . Under her tenure, SNAL’s revenue increased from FY2023 to FY2024 and EBITDA returned to positive in 2024 (see Performance & Track Record) [Values retrieved from S&P Global].

Past Roles

OrganizationRoleYearsStrategic impact
Snail, Inc.Chief Financial Officer; Secretary; DirectorCFO since Sep 2020; Director since Jan 11, 2022Leads finance and SEC reporting; board oversight and corporate secretary responsibilities
The Pun Group, LLPPartnerAug 2015 – Sep 2020Led public company audit/advisory engagements; prepares executive for public company finance rigor
Ernst & YoungManagerJul 2014 – Jun 2015Managed audit/advisory work at Big Four, enhancing controls/GAAP expertise

External Roles

OrganizationRoleYearsNotes
Franklin Wireless Corp.Director; Chair of Audit CommitteeSince Dec 2019Public company audit committee chair experience
VirnetX Holding CorporationIndependent Board MemberSince Jun 2024Independent directorship in technology/IP company

Fixed Compensation

Metric202220232024
Base Salary ($)380,000 380,000 380,000
Stock Awards ($)1,310,000 (IPO PSUs grant-date fair value)
All Other Compensation ($)16,423 15,329 17,716
Total ($)1,706,423 395,329 397,716

Notes: 2024 “All Other Compensation” for Ms. Chow includes 401(k) match $8,284, healthcare $8,782, and phone allowance $650 . As an emerging growth company, SNAL provides reduced executive compensation disclosures and is exempt from say‑on‑pay .

Performance Compensation

ComponentMetricTranches (Vesting %)Trigger/TargetVesting DatesStatus DisclosureGrant Details
Performance Stock Units (PSUs)“Average Annual Growth Rate” (AAGR) as defined in award10%AAGR ≥ 15% over 1-year post-IPONov 9, 2023Not disclosedMs. Chow was granted 262,080 PSUs on Nov 9, 2022 under the 2022 Plan
15%AAGR ≥ 30% over 2 yearsNov 9, 2024Not disclosedSee vesting mechanics
20%AAGR ≥ 45% over 3 yearsNov 9, 2025Not disclosed
25%AAGR ≥ 60% over 4 yearsNov 9, 2026Not disclosed
30%AAGR ≥ 75% over 5 yearsNov 9, 2027Not disclosedIf 75% AAGR achie ved before year 5, all unvested PSUs vest

Additional details and plan oversight:

  • PSUs were one-time “IPO Founder Grants” under the 2022 Omnibus Incentive Plan; no additional PSUs were granted to Ms. Chow in 2023 or 2024 .
  • No option awards have been granted to NEOs as of the record date .

Equity Ownership & Alignment

ItemDetail
Beneficial ownership (common)Ms. Chow reported no beneficial ownership of Class A or Class B common shares as of April 22, 2025 .
Unvested PSUs outstanding262,080 PSUs; market value $487,469 at $1.86 close on 12/31/2024 .
Options (exercisable/unexercisable)None disclosed; no option awards outstanding in tables .
Ownership guidelinesNot disclosed in proxy.
Pledging/hedgingNo pledging by Ms. Chow is disclosed. SNAL’s Insider Trading Policy prohibits trading on MNPI, allows Rule 10b5‑1 plans with pre‑clearance; hedging/pledging prohibitions are not explicitly described in the proxy .

Employment Terms

TermDetails
Employment agreementOffer letter dated Aug 18, 2020; employed at-will .
Base salary$380,000 .
Bonus eligibilityEligible for annual cash/equity bonuses at Board discretion under the 2022 Plan .
Non-compete / Non‑solicitMs. Chow agreed not to compete during employment and not to solicit customers/employees for two years post-termination .
Severance / Change‑of‑ControlNot disclosed in proxy.
ClawbackNot disclosed in proxy.
Insider trading policyPre-clearance required for insiders; blackout periods enforced; 10b5‑1 trading plans permitted .

Board Governance

AspectDetails
Board serviceDirector since Jan 11, 2022; also Director of Snail Games USA, Inc. since Nov 2021 .
Committee rolesChair, Nominating & Corporate Governance Committee; Member, Compensation Committee .
IndependenceSNAL is a controlled company under Nasdaq rules; only 3 of 8 directors are independent (37.5%). Ms. Chow is not independent and serves on the Compensation Committee under controlled-company exemptions .
Board attendanceIn FY2024, the Board met five times; each director attended ≥75% of applicable meetings .
Executive sessionsIndependent directors typically hold an executive session at each quarterly meeting .
Dual-role implicationsCFO serving as Director, Chair of Nominating & Governance, and member of Compensation Committee raises independence considerations; permitted under controlled‑company exemptions but atypical for non‑controlled companies .

Director Compensation (context)

  • Non-employee directors receive cash retainers ($40k; chair and committee chair supplements) and RSUs; NEOs (like Ms. Chow) are excluded from the non-employee director compensation program .
  • Independent directors’ RSUs vest quarterly; forfeited if service ends; details in policy .

Performance & Track Record

SNAL financial performance during Ms. Chow’s tenure as CFO:

Metric (USD)FY 2022FY 2023FY 2024
Revenue74,444,14160,902,09884,467,047
EBITDA6,596,092*-8,475,416*4,200,608*

Values retrieved from S&P Global.

  • Asterisk indicates values retrieved from S&P Global without document citations.

Implications:

  • Revenue increased in 2024 vs. 2023; EBITDA turned positive in 2024, potentially improving the outlook for performance-based equity vesting (subject to AAGR definitions in award agreements) [Values retrieved from S&P Global] .

Compensation Structure Analysis

  • Mix and trend: 2022 total pay was equity-heavy due to IPO PSUs; 2023–2024 comp was predominantly fixed salary with modest perquisites; no new stock awards to Ms. Chow disclosed in 2023–2024 .
  • Performance linkage: PSUs vest only if multi‑year AAGR hurdles are met; if the 75% AAGR is achieved anytime in the 5-year window, remaining unvested PSUs vest in full, aligning pay with rigorous growth outcomes .
  • Option usage: None; shift is to PSU/RSU rather than options (lower leverage, longer retention) .
  • Discretionary bonuses: Eligibility disclosed; specific targets/weightings for annual bonuses not disclosed .
  • Clawback/CoC: Not disclosed—limits visibility on recourse and parachute economics.

Risk Indicators & Red Flags

  • Governance concentration: Controlled company status; Chair/Co‑CEO (Hai Shi) and spouse (Ying Zhou) control 97.14% voting power through Class B shares; only 37.5% independent directors .
  • Committee independence: CFO (non‑independent) serves on Compensation Committee and chairs Nominating & Governance under controlled‑company exemptions—potential independence concerns .
  • Related‑party transactions: Significant licensing/payments with SDE (controlled by director Ying Zhou); while not tied to Ms. Chow personally, such transactions elevate governance scrutiny .
  • Pledging/hedging: No disclosure of pledging by Ms. Chow; insider trading policy permits 10b5‑1 plans with pre‑clearance .
  • Say‑on‑Pay: Exempt as EGC, limiting shareholder feedback loop on pay practices .

Equity Ownership & Alignment Detail

CategoryShares / $Notes
Beneficial ownership (Class A)0As of Apr 22, 2025
Beneficial ownership (Class B)0As of Apr 22, 2025
Unvested PSUs (12/31/2024)262,080IPO Founder Grant; unearned at target count basis
Market value of unvested PSUs (12/31/2024)$487,469262,080 × $1.86 close
Options (exercisable/unexercisable)0 / 0No options disclosed
Ownership guidelinesN/ANot disclosed in proxy

Committee & Compensation Governance

ItemDetails
Compensation CommitteeYing Zhou (Chair), Neil Foster (independent), Heidy K. Chow (CFO); met once in 2024; charter allows independent advisors .
Nominating & GovernanceHeidy K. Chow (Chair), Peter Kang, Sandra Pundmann; no meetings in 2024; charter authority to retain advisors .
Audit CommitteeIndependent: Sandra Pundmann (Chair; financial expert), Neil Foster, Ryan Jamieson .

Investment Implications

  • Alignment: Ms. Chow’s 2022 PSU grant creates multi‑year, performance‑contingent upside; no additional equity grants in 2023–2024 and zero reported beneficial ownership of common stock reduce immediate insider selling pressure but also lower near‑term “skin in the game” aside from PSUs .
  • Retention: A two‑year post‑termination non‑solicit and PSU vesting cliffs tied to AAGR targets promote retention; absence of disclosed severance/CoC terms limits visibility on exit costs .
  • Governance risk: Controlled‑company structure and CFO’s dual roles (director; comp committee member; nominating committee chair) elevate independence concerns; ongoing related‑party transactions require continued monitoring .
  • Performance: FY2024 inflection in EBITDA and stronger revenue provide a better backdrop for achieving PSU thresholds, but vesting outcomes depend on award‑defined AAGR calculations not disclosed in the proxy [Values retrieved from S&P Global] .

S&P Global disclaimer: Financial values in the Performance & Track Record table are retrieved from S&P Global. EBITDA values are marked with an asterisk to indicate no document citations.