This excerpt taken from the ADM DEF 14A filed Sep 25, 2009.
Equity Grants made in September 2009 (reflecting FY07-FY09 performance)
(These grants will be presented in the Grants of Plan-Based Awards table in our 2010 proxy statement.)
Does The Company Have A Policy For When Grants Are Made?
The Committee grants all equity awards to named executive officers, and no attempt is made to time the granting of these awards in relation to the release of material, non-public information. The exercise price of all stock options is set at fair market value (as determined in accordance with the applicable Incentive Compensation Plan) on the grant date. Under the 2002 Incentive Compensation Plan and proposed 2009 Incentive Compensation Plan, fair market value is the closing market price on the last trading day prior to the date of grant. The Committee meets during the first fiscal quarter of the following fiscal year and determines the annual equity awards granted to named executive officers. These awards are issued promptly following the date of the Committees meeting and approval. In addition to annual awards, the named executive officers may receive awards when they join the company or change their status, including promotions.