Unofficial translation by the Financial and Capital Market Commission
Financial and Capital Market Commission Regulation No. 126
Riga, 2 July 2014
(Financial and Capital Market Commission
Supervisory Board Meeting Minutes No. 24, Clause 2)
Regulation on Core Principles of the Remuneration Policy
Issued in accordance with Section 341, Paragraph two and Section 343, Paragraph seven of the Credit Institutions
Law and
Section 124, Paragraph 11 and Paragraph 17 of the Financial Instruments Market Law
1. Introduction
1. Regulation on Core Principles of the Remuneration Policy (hereinafter - the Regulation)
shall lay down the core principles of the remuneration policy and shall be binding on credit
institutions and investment firms registered in the Republic of Latvia, which, by virtue of the
licence, are allowed to provide investment services mentioned in Section 3, Paragraph four,
Clauses 5 and 6 of the Law on the Financial Instruments Market. The core principles of the
remuneration policy laid down by the Regulation are recommended for application to other
investment firms, insurance undertakings and reinsurance undertakings, as well as investment
management companies and private pension funds.
2. The institution shall observe the requirements of this Regulation individually and on the
consolidated or sub-consolidated level in accordance with its organisational structure, nature,
scope, complexity and specificity of the activities thereof.3. The institutions bound by the
requirements of this Regulation shall observe the requirements laid down in Clause 21 of this
Regulation individually, if they are not subject to consolidated supervision carried out by the
Financial and Capital Market Commission (hereinafter – the Commission) or the supervisory
authority of another Member State, or on consolidated or sub-consolidated level, if they are
subject to consolidated supervision carried out by the Commission, but are not subject to
consolidated supervision carried out by the supervisory authority of another Member State.
4. Terms used in the Regulation:
4.1. internal control functions – risk control, compliance and internal audit functions in the
institution;
4.2. variable remuneration component – part of the remuneration that depends on the
performance;it may comprise various elements, for example, paid out in monetary (for
example, bonus) or non-monetary form (for example, in the form of shares or share-linked
instruments). The variable remuneration component shall also include the discretionary
pension benefits of the institution, where the amount depends on performance, but it does not
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include such contributions to the pension plans of private pension funds or such pension
expenses, that are established in accordance with the pension policy of the institution at the
level of organisation;
4.3. remuneration – sum of the fixed remuneration component (usually – work salary) and
variable remuneration component (if any);
4.4. significant variable remuneration component - variable remuneration component
comprising 70 per cent to 100 per cent (excluding) of the fixed remuneration component set
for the officer or the employee for the reporting year;
4.5. particularly high variable remuneration component - variable remuneration component
comprising 100 per cent (including) and more of the fixed remuneration component
determined for the officer or the employee for the reporting year;
4.6. investment service providers – natural persons, employees of the institutions involved in
the process of providing investment services or ancillary services mentioned in Section 3,
Paragraphs four and five of the Law on Financial Instruments Market, including client service
specialists, sales specialists, financial analysts and other persons having material influence on
the quality of the investment service or the ancillaryservice.
5. The requirements of this Regulation shall apply to:
5.1. positions whose professional activity individually or collectively has material influence
on the risk profile of the institution, for example, positions such as management board
members or senior management, positions whose powers include the rights to take such risks
on behalf of the institution, which have material influence on the risk profile of the institution,
positions carrying out internal control functions in the institution, as well as positions whose
remuneration is equal to or exceeds the lowest remuneration level scale of the positions of the
management board members of the institution or of the positions whose powers include the
rights to take such risks on behalf of the institution, which have material influence on the risk
profile of the institution (hereinafter also referred to as the positions having influence on the
risk profile of the institution);
5.2. investment service providers.
6. The institution shall ensure that:
6.1. the officers and employees undertake not to use personal risk hedging strategies or such
remuneration and liability insurance, which would reduce the risk of the effect of the potential
adjustments laid down in the remuneration policy on the remuneration;
6.2. when performing the pay-out of the variable remuneration component, no tools or
methods are applied, which encourage circumvention of the requirements of this Regulation
or Regulation (EU) No. 575/2013 of the European Parliament and of the Council of
26 June 2013 on prudential requirements for credit institutions and investment firms and
amending Regulation (EU) No. 648/2012 (hereinafter – EU Regulation No. 575/2013).
7. The institution shall introduce appropriate measures ensuring the observance of the
requirements of this Regulation, when calculating the remuneration for third parties (for
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example, outsourced agents) for the provision of investment services or ancillary services
within the meaning of the Law on Financial Instruments Market, to the client of the
institution. If the institution outsources investment services or ancillary services, the
institution shall verify that the remuneration policy of the outsourced service provider
complies with the requirements of this Regulation.
2. Remuneration Policy
2.1. Governance
8. The institution shall ensure the development, introduction and continuous maintenance of
such a remuneration policy, which:
8.1. does not encourage risk-taking above the risk-taking level stated in the risk strategy of the
institution;
8.2. does not restrict the ability of the institution to strengthen its own funds;
8.3. corresponds to the values of the institution, for example ethical standards, long-term
interests, objectives of the activities prescribed by the development strategy, as well as is
consistent with and facilitates prudent and effective risk management and the prevention of
conflicts of interest;
8.4. is not contrary to the principles of protecting the interests of clients or investors, or other
stakeholders;
8.5. considers that the setting of guaranteed variable remuneration component does not
correspond to prudent risk management or the linking variable remuneration component to
performance in line with the requirements of this Regulation, and it may not be provided for
in the prospective remuneration plans. The guaranteed variable remuneration component may
only be set as an exception in cases of hiring new officers or employees during the period of
the first year of employment, provided that it does not impede the institution from
maintaining a sound and strong capital base.
9. The supervisory board of the institution shall be responsible for:
9.1. laying down the core principles of the remuneration policy and approval of the
remuneration policy;
9.2. supervision of the development and implementation of the remuneration policy;
9.3. setting of remuneration of the members of the management board, employees heading
the internal audit function of the institution, as well as of the positions whose remuneration is
equal to or exceeds the lowest remuneration level scale of the management board members of
the institution. If the institution receives state support, the supervisory board of the institution
shall immediately review the remuneration of the management board members of the
institution and other positions having influence on the risk profile of the institution, in line
with justified and effective risk management and long-term growth, as well as shall perform
follow-up review in accordance with the changes in the financial situation of the institution;
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9.4. direct supervision of remuneration of officers or employees heading the risk control or
compliance functions;
9.5. regular, but at least annual review of the core principles of the remuneration policy, to
ensure its compliance with the current activities of the institution and its development
strategy, as well as the changes in external factors;
9.6. laying down the procedure for the performance of audit on the implementation of the
remuneration policy versus the approved remuneration policy (for example, the supervisory
board of the institution shall determine that the internal control functions perform the audit
regularly, but at least on an annual basis);
9.7. setting of the procedure for reporting to the supervisory board on audits performed by the
internal control functions and conclusions reached, as well as on the impact of the
remuneration policy on the risk profile and quality of risk management of the institution.
10. The management board of the institution shall be responsible for the development of the
remuneration policy in accordance with the core principles of the remuneration policy laid
down by the supervisory board of the institution and development and approval of
corresponding internal regulations and their implementation. Remuneration of the internal
control functions shall be determined in accordance with the achievement of the objectives set
for the internal control functions, irrespective of the performance of the business functions
they control.
The management board of the institution shall ensure that the officers and employees are
informed about indices and methods applied in the assessment of their performance and
setting of the variable remuneration component, as well as shall ensure that the internal
regulations on the setting of remuneration, including assessment process and results thereof
are clear, documented and internally available, insofar as it is necessary for the performance
of functions or job responsibilities or insofar as they refer to the particular officer or
employee.
11. The institution, taking into account the scope, nature, complexity and specificity of its
activities as well as its organisational structure, shall assess the feasibility of establishing a
remuneration committee. The remuneration committee shall be responsible for the preparation
of internal regulations approved by the supervisory board of the institution and related to the
remuneration, including the preparation of such internal regulations, which impact the risk
profile and quality of risk management of the institution. The remuneration committee shall
prepare internal regulations, taking into account the long–term interests of the shareholders,
investors and other stakeholders of the institution, as well as the interests of the general
public.
In accordance with the authorisation from the supervisory board of the institution the
remuneration committee of the institution may also be responsible for the determination of
remuneration for management board members of the institution, officers or employees
heading the internal audit function, positions whose remuneration is equal to or exceeds the
lowest remuneration level scale of the management board members of the institution, as well
as for the direct supervision of remuneration of the senior officers or employees of the risk
control and compliance functions.
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One of the members of the supervisory board of the institution shall be appointed as the head
of the remuneration committee. Only the members of the supervisory board of the institution
may be appointed as members of the remuneration committee, unless laws and regulations
provide for representation in the supervisory board of the institution of the officer, other than
a member of the supervisory board of the institution, or an employee. In such a case the
officer, who is not a member of the supervisory board of the institution, or the employee of
the institution may also be appointed as the member of the remuneration committee.
The institution shall ensure that the assessment and decisions adopted on the feasibility of
establishing the remuneration policy are documented and substantiated.
12. The development, introduction and ensuring compliance with the remuneration policy and
internal regulations related thereto shall also involve the officers or employees performing the
internal control functions in the institution, and the officers and employees performing the
human resources management function in the institution, as well as, if necessary, the
shareholders and external experts. The involved officers or employees, members of the
remuneration committee, shareholders, external experts, as well as the members of the
supervisory board in charge of the remuneration policy of the institution must:
12.1. have appropriate competence;
12.2. be functionally independent from the fields of activities (units) subject to their control;
12.3. have the necessary powers for the performance of their functions and obtaining
information;
12.4. be able to provide independent and competent assessment on the remuneration policy
and the compliance thereof, as well as the its suitability to the activities of the institution,
including the impact on the risk profile and the quality of the risk, capital and liquidity
management of the institution.
2.2. Core Principles of the Remuneration Policy
13. The core principles of the remuneration policy shall set:
13.1. the objectives of the remuneration policy, for example, achievement of operating
objectives set by the institution, i.e., attraction and motivation of the officers or employees of
the relevant qualification;
13.2. remuneration elements, including, including work salary, incentive scheme for
achievement of the long-term performance, shares, share–linked instruments or other
instruments corresponding to the requirements mentioned in Clause 19.2.2 of this Regulation,
compensation in the case of termination of the employment contract or authorisation contract,
contributions into pension plans of private pension funds, discretionary pension benefits and
other pension expenses in accordance with the pension policy of the institution, payments
related to the indemnification or discharge of the liabilities of the officer or employee arising
out of the termination of the authorisation contract or employment contract concluded with
the previous employer and corresponding to the long-term interests of the institution, inter
alia, non-monetary instrument retention policy in line with the requirements of Clause 19.2 of
this Regulation, procedure for the deferral of significant and particularly high variable
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remuneration component in line with the requirements of Clause 19.1 of this Regulation,
adjustment mechanisms of the variable remuneration component in line with the requirements
of Clause 19.3.1 of these Regulation, as well as performance, etc.
13.3. financial and non-financial indicators and methods for the assessment of performance of
the officers and employees and the setting of the variable remuneration component and fixed
remuneration component. The institution shall clearly separate the indicators applied to
determine:
13.3.1. fixed remuneration component primarily reflecting the professional experience and
level of responsibility of the officer or employee laid down in the job description of the
relevant officer or employee forming an integral part of the employment contract;
13.3.2. variable remuneration component reflecting the performance of the officer or
employee exceeding the requirements laid down in his / her job description forming an
integral part thereof, stability thereof and assessment of existing and probable risks associated
thereto;
13.4. measures for the prevention of the conflict of interest, for example, excluding the
possibility for the members of the management board of the institution to set or take part in
setting their remuneration or directly linking the remuneration to the sales of specific financial
instruments, categories or particular volumes of the financial instruments;
13.5. with respect to each officer or employee –an appropriate balance betweenfixed and
variable remuneration components, including the structure of the variable remuneration
component and the highest amount orpercentage of the variable remuneration component,
taking into account the conditions and specificity of the field of activities, where the relevant
officer or employee operates. The institution shall ensure that the variable remuneration
component in the remuneration is sufficiently large for the institution to be able to implement
a flexible remuneration policy in respect to the variable remuneration component, including
the possibility not to pay out the variable remuneration component, for example in the case of
deterioration of the financial situation of the institution and the solvency thereof, taking into
account the considerations of ensuring long-term capital adequacy;
13.6. conditions for the reduction or non-disbursement of remuneration exceeding the
amounts of severance pay prescribed by the Labour Law in the case of notice of termination
of the employment contract or authorisation contract, if errors or deficiencies, or misconduct
has been revealed for during the period of activity of the respective officer or employee;
13.7. positions having influence on the risk profile of the institution, ensuring that the
assessment and decisions adopted on the determination of the positions having influence on
the the risk profile of the institution are documented.
2.3. Assessment of Performance and Setting of the Variable Remuneration Component
14. The assessment of performance shall not only employ financial indicators characterising
the volume of the activities, for example, income or turnover. If the assessment of
performance employs financial indicators calculated on the basis of accounting data, the
institution shall take into account that such indicators include performance for the previous
periods, but do not take into account the risks which might trigger losses in the subsequent
periods. Financial indicators shall be adjusted, taking into account:
14.1. assessment of the current and probable risks associated with the performance;
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14.2. capital expenses, as well as expenses of ensuring liquidity;
15. When developing methods for the adjustment of financial indicators, it is recommended to
state how the following elements shall be reflected in the setting of the variable remuneration
component for each officer or employee:
15.1. risks which occur or might occur in the types of activities where the respective officer or
employee is employed;
15.2. internal control elements for mitigating current and probable risks;
15.3. the period necessary to be able to assess the result of the type of activities where the
respective officer or employee is employed.
16. Non-financial indices shall be applied for assessing the performance (for example,
compliance with internal regulations and standards prescribing client and investor relations,
or the prescribed limits, fair treatment of clients, client satisfaction), and they shall be taken
into account when assessing the individual performance of each officer or employee. When
determining the meaning of the non-financial indicators, the institution shall take into account
that the use of the non-financial indicators in the assessment of individual performance is
significant, because the failure to comply with (or fully comply with) the non-financial
indicators might affect the risk profile of the institution or its financial performance.
17. In the setting of the variable remuneration component, the assessment of the performance
of the officer or employee is takes into account individual performance in combination with
the assessment of performance at the level of the respective structural unit and in combination
with the overall performance at the level of the institution, consolidation or sub-consolidation
group, as well as the expert assessments , for example, risk control function regarding
stability (consistency) of performance.
18. The institution shall develop indicators to be used for the calculation and adjustment of
variable remuneration components or pools of variable remuneration components, taking into
account the considerations mentioned in Clause 14.1 and 14.2 of this Regulation. The
institution shall ensure that the variable remuneration components are aligned within the
institution, taking into account the assessment of current and probable risks associated with
performance of the respective alignment level.
2.4. Requirements in respect to the Positions Having Influence on the Risk Profile of the
Institution
19. The core principles of the remuneration policy with respect to the positions that have
influence on the risk profile of the institution shall additionally prescribe:
19.1. procedure for the deferral of significant and particularly high variable remuneration
component, taking into account that, in the case of the setting of a significant variable
remuneration component, at least 40% (in the case of the setting of a particularly high
variable remuneration component – at least 60% ) thereof are deferred for a period of at least
three to five years, depending on the position or level of responsibility, and during which the
performance, for the period to which the variable remuneration component applies, its
stability and the associated risks can be assessed. The deferral period of the variable
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remuneration component shall be determined in accordance with the business cycle, type of
business, its risks and actions of the involved officer or employee;
19.2. procedure for setting a particularly high variable remuneration component, taking into
account that if capital instruments of the institution are traded in a regulated market, then, in
the case of the setting a particularly high variable remuneration component, at least 50 per
cent thereof shall be determined in a non-monetary form, comprised of:
19.2.1. shares or share-linked instruments;
19.2.2. if possible, instruments complying with the requirements of Article 52 and 63 of EU
Regulation No. 575/2013 or other instruments which can be fully converted into Tier 1 capital
instruments or written down, and which, in any case, appropriately reflect the credit quality of
the institution as a going concern, as well as are suitable for use for the purposes of setting the
variable remuneration component.
With respect to the instruments mentioned in this Clause the institution shall set the retention
policy of non-monetary instruments corresponding thereto, i.e., the number of years during
which the recipient of the respective non-monetary instruments is not entitled to sell them, in
order to ensure the consistency of the incentive schemes laid down in the remuneration policy
of the institution with the long-term interests of the institution.
19.3. conditions for pay-out of the variable remuneration component corresponding to each
position having influence on the risk profile of the institution, irrespective of the its structure
(shares of the institution, share–linked instruments, cash and other forms of payment) and the
obtaining of irrevocable rights thereto, taking into account that:
19.3.1. the variable remuneration component, including the deferred part, shall be paid out ,
or vest in line with the requirements of Clause 19.3.2 of this Regulation, in accordance with
the business cycle of the institution and the risks of activities, only if the financial situation
and performance of the institution, the performance of the person in the position having
influence on its risk profile and the performance of the respective structural unit support such
payment. The institution shall reduce the pay-out of the total amount of the variable
remuneration component, including the pay-out of any amountof the deferred part of the
variable remuneration component, if the financial performance of the institution deteriorates
or is negative. The institution shall ensure the application of such adjustment mechanisms as
requesting return of the paid out variable remuneration component or partial or full reduction
of the total amount of the deferred part of the variable remuneration component, if it has been
granted for performance, on the basis of data, which subsequently turned out to be
intentionally misrepresented (clawback), or reduction of the deferred part of the variable
remuneration component which has not vested on the basis of actual performance (malus).
The institution shall set the criteria for the application of adjustment mechanisms and shall
ensure that they cover the situations where the respective officer or employee took part in or
was in charge of the conduct, as a result whereof the institution incurred material losses, or
the situations where the respective officer or employee did not correspond to the standards of
fitness and propriety.
19.3.2 The variable part of remuneration vests on pro rata basis (proportionally to the number
of years) depending on the number of years of the deferral of the variable remuneration
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component, but no sooner than 12 months after the setting of the variable remuneration
component. Before vesting, the variable remuneration component is subject, if necessary, to
an ex-post risk adjustment, which takes into consideration the risks that have been identified
during the deferral period (and therefore have not been part of the initial calculation) and the
risks relating to the performance results, for which the deferred part of the variable
remuneration component has been granted. The institution is responsible for ensuring that the
pay out of the deferred part of the variable remuneration component take place only after
vesting and no dividends or interest is paid on the amounts that have not vested. 19.3.3. when
carrying out the pay-out of a particularly high variable remuneration component, including
the deferred part thereof, the requirements of Clause 19.2 of this Regulation shall be applied
to both the deferred part and the upfront part of the variable remuneration component;
19.4. conditions for the pay-out of discretionary pension benefits comprising the element of
the variable remuneration component, taking into account the following requirements, if
capital securities of the institution are traded in the regulated market:
19.4.1. if employment relationships are terminated before retirement, the institution shall
ensure the retention of discretionary pension benefits in a non-monetary form in its ownership
for at least five years, i.e., the discretionary pension benefits in a non-monetary form shall be
paid out five years after the termination of employment relationships prior to retirement;
19.4.2. when the officer or employee reaches retirement age, the institution shall ensure that
the discretionary pension benefits are paid out in a non-monetary form and are subject to the
policy on retention of the non-monetary instrument laid down by the institution, taking into
account that the retention period of the said instruments may not be shorter than five years,
i.e., the officer or employee may sell the received discretionary pension benefits in a nonmonetary form not earlier than five years after reaching retirement age;
19.5. When determining the variable remuneration component, multi-year performance
indicators shall be considered, in order to ensure that the assessment of performance is
supported by long-term performance.
3. Disclosure of Information on the Remuneration Policy and Reporting
20. The institution shall disclose information about its remuneration policy and practices for
the reporting period commencing on 1 January 2014 and later, in line with the requirements
of Article 450 of EU Regulation No. 575/2013 and by filling out the table attached in
Annex I. The table shall be filled out, taking into account the following requirements:
20.1. the report shall be prepared for the reporting year for the consolidation or subconsolidation group, or individually;
20.2. the report shall specify the gross remuneration, except for mandatory social security
contributions by the employer;
20.3. total amounts in the report shall be reflected in full euros; the remuneration reflected in
the foreign currency shall be converted into euros in accordance with the foreign currency
exchange rate applied in accounting;
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20.4. number of employees in the reporting year in the full time equivalent at the end of the
year, except for information about the supervisory board and management board members.
With respect to the supervisory board and the management board the number of elected
members shall be specified.
The institutions shall submit this information to the Commission and shall publish in
compliance with the laws and regulations in the field of the protection of personal data of
natural persons by the 1 May of the year following the reporting year.
21. The institution shall submit information to the Commission in line with the table attached
in Annex 2 of this Regulation, regarding such officers or employers whose remuneration in
the reporting year is equal to or exceeds 1 million euros (hereinafter – high earners), taking
into account the following requirements:
21.1. the report of the institution mentioned in Clause 3 of these Regulation with respect to
each Member State where it carries out its business and which employs at least one high
earner shall be prepared separately;
21.2. information about the high earner shall be included in the report prepared in respect to
the Member State where the respective employee carries out his / her professional activities;
21.3. information about the high earner carrying out his / her professional activities in several
Member States shall be included in the report prepared in respect to the Member State where
the respective employee primarily carries out his / her professional activities. Information
about the high earner carrying out his / her professional activities both in the Member State
and in the foreign country shall be included in the report prepared with respect to the
particular Member State, if the high earner carries out his / her professional activities
primarily in this Member State and not in the foreign country;
21.4. the report shall be prepared for the reporting year;
21.5. total amounts in the report shall be reflected in full euros. The remuneration reflected in
foreign currency shall be converted into euros in accordance with the foreign currency
exchange rate applied in accounting;
21.6. the report shall not include information about high earners carrying out their
professional activities in foreign countries.
The institution shall submit the report to the Commission by the 31 March of the year
following the reporting year. The institution may not prepare the report and to submit it to the
Commission if there are no high earners in any of the European Economic Area countries
where the institution mentioned in Clause 3 of this Regulation carries out its activities.
Additionally, the institutions shall disclose information about the number of high earners
in accordance with the requirements of Clause (i) of Article 450 of EU Regulation
No. 575/2013.
22. Reports mentioned in Clauses 20 and 21 of the Regulation shall be prepared in
accordance with the procedure prescribed by the Commission’s Regulation of
14 October 2008 No. 146 Regulation on the Submission of Reports Prepared in Electronic
Form. If the Commission detects that the report is prepared erroneously, the submitter of the
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report shall be notified thereon. Unless the Commission has specified another term, the
corrected report shall be submitted not later than on the second business day after the receipt
of the notice of the existence of errors from the Commission.
4. Final Provision
23. To recognise as null and void the Financial and Capital Market Commission's Regulation
of 21 December 2009 No. 171 Regulation on Core Principles of the Remuneration Policy.
Informative reference to the Directive of the European Union
The Regulation incorporates the legal provisions arising out of Directive 2013/36/EU of the
European Parliament and of the Council of 26 June 2013 on access to the activity of credit
institutions and the prudential supervision of credit institutions and investment firms,
amending Directive 2002/87/EC and repealing Directive 2006/48/EC and 2006/49/EC.
Deputy Chairman of the Financial and Capital Market Commission P. Putniņš
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Annex 1
Name of the institution or consolidation group:
Reporting period:
Table 1 Information on remuneration for all staff
Total
Number of Members (Headcount)
Total number of staff in FTE
Total net profit in year N (in EUR)
Total remuneration (in EUR)
Of which: variable remuneration (in
EUR)
Supervisory
Board
Management
Board
Investment
banking
Retail
banking
Asset
management
Corporate
functions
Independent
control
functions
All
other
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Table 2 – Information on remuneration of staff having influence on the risk profile of the institution
Supervisory
Board
Members (Headcount)
Number of staff in FTE
Number of staff in senior
management positions
Total fixed remuneration (in EUR)
Of which: fixed in cash
Of which: fixed in shares and sharelinked instruments
Of which: fixed in other types
instruments7
Total variable remuneration (in EUR)
Of which: variable in cash
Of which: variable in shares and
share-linked instruments
Of which: variable in other types
instruments7
Total amount of variable
remuneration awarded in year N
which has been deferred (in EUR)
Of which: deferred variable in cash
in year N
.
Management
Board
Investment
banking1
Retail
banking2
Asset
management3
Corporate
functions4
Independent
control
functions5
All other6
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Of which: deferred variable in shares
and share-linked instruments in year
N
Of which: deferred variable in other
types of instruments7 in year N
.
.
Additional information regarding the amount of total variable remuneration
Art 450 h(iii)CRR; total amount of
outstanding deferred variable
.
remuneration awarded in previous
periods and not in year N (in EUR)
Of which: vested
Of which: not vested
Total variable remuneration paid out
in Year N
Total amount of explicit ex post
performance adjustment applied in
Year N for previously awarded
remuneration (in EUR)
Number of beneficiaries of
guaranteed variable remuneration
(new sign on payments)
Total amount of guaranteed variable
remuneration (new sign on
payments) (in EUR)
.
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Number of beneficiaries of severance
payments
Total amount of severance payments
paid in year N (in EUR)
Art 450 h(v) Highest severance
payment to a single person (in EUR)
Number of beneficiaries of
contributions to discretionary
pension benefits in year N
Total amount of discretionary
pension benefits (in EUR) in year N
.
Including corporate finance advice services, private equity, capital markets, trading and sales.
Including total lending activity (to individuals and enterprises).
3
Including portfolio management, managing of UCITS in accordance with Directive 2009/65/EC and other forms of asset management.
4
All functions that have responsibilities for the whole institution on consolidated level and for subsidiaries with such functions on solo level, e.g. Human Resources, IT.
5
Officers or employees active in the independent risk control, compliance and internal audit function
6
Officers or employees who cannot be mapped into one of the other business areas. The institution adds explanation on the activities performed by such officers or
employees
2
7
Instruments that correspond to the requirements of Clause 18.2.2.
Signature of the Chairperson of the institution
Name and contact details of the responsible employees
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Annex 2
Report on high earners
Name of the institution:
Member State:
Reporting year:
Responsible employee:
Phone:
E-mail:
Field of activity:
Investment
banking1
Retail banking2
Asset management3
All other4
Total number of high
earners5, including.:
Employees having
influence on the risk
profile of the institution
Total fixed
remuneration (euro)
Total variable
remuneration6 euro),
including:
Total discretionary
pension benefits
Total deferred
remuneration
Explanation on the activities of high earners included under "All other":
1
Including corporate finance advice services, private equity, capital markets, trading and sales.
2
Including total lending activity (to individuals and enterprises).
3
Including portfolio management, managing of UCITS in accordance with Directive 2009/65/EC and
other forms of asset management.
Unofficial translation by the Financial and Capital Market Commission
4
Includes high earners who are not performing investment banking, retail banking or asset
management activities. In such cases the institution adds explanatation on the professional activities
performed by the high earner.
5
6
Number of high earners (in full time equivalent) on 31 December of the reporting year.
includes variable remuneration component including the remuneration deferred, discretionary pension
benefits, guaranteed variable remuneration and severance pay that exceeds the severance pay
prescribed by the Labour Law in the case of notice of termination of the employment contract or
authorisation contract