Response to consultation on Guidelines on remuneration policies for investment firms

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Question 1: Are the subject matter, scope and definitions appropriate and sufficiently clear?

The subject matter, scope and definitions are clear.

Question 2: Is the section on gender neutral remuneration policies sufficiently clear?

We believe that it is clear, however we would suggest to further strengthen the language on equal value of work, drawing inspiration from documents such as, Commission Recommendation C(2014) 1405 final, para 10, or Commission Staff Working Document SWD/2013/0512 final. Especially when it comes to topics such as severance pay and evaluation of value of work based on the contract type in question, we believe that great care must be shown to ensure the promotion of equality and impartiality.

Question 3: Are the sections on the remuneration committee sufficiently clear?

Yes and UNI Europa Finance warmly welcomes the specific reference made to including employee representatives on the committees. We do however emphasize, that where national and sectoral collective agreements have been reached, these should form the base for the work of the remuneration committee.

Question 4: Are the guidelines on the application of the requirements in a group context sufficiently clear?


Question 5: Are the guidelines regarding the application of waivers within section 4 sufficiently clear?


Question 6: Is section 9 on severance payments sufficiently clear?


Question 7: Are the provisions on performance criteria sufficiently clear, which other performance indicators, e.g. regarding the performance of business units or portfolios, are used to determine the variable remuneration of identified staff?


Question 8: Is the section on the pay out in instruments sufficiently clear?


Name of the organization

UNI Europa Finance