Which of the following companies has the highest payout ratio?

a company with $37 million cash dividends declared on common shares and a net income of $102 million

a company with $68 million cash dividends declared on common shares and a net income of $205 million

a company with $43 million cash dividends declared on common shares and a net income of $164 million

a company with $29 million cash dividends declared on common shares and a net income of $95 million