Response to consultation Paper on draft Guidelines on the remuneration benchmarking exercise

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Q3: Is the scope of consolidation for the data to be reported sufficiently clear?


Q5: Is the template in Annex 1 appropriate and sufficiently clear?


Q6: Is the template in Annex 2 appropriate and sufficiently clear?

Yes, we would like to point in particular to the relevance of the rows “number of identified staff in FTE”, and “number of identified staff in senior management positions” in the template in Annex II. This is important for us in order to monitor whether the range of employees to whom the remuneration policy is applied is not expanded beyond what was envisaged by the legislator. Although we recognise that both should not necessarily be identical, the unlikely situation of a high difference between the two could indicate that a financial institution applies the remuneration policy so broadly that it infringes upon the staff normally covered by collective bargaining.

Q7: Is the template in Annex 3 appropriate and sufficiently clear?


Q8: Are the reporting period, the specific amounts to be reported and the currency conversion sufficiently clear?


Q9: Are the indicated time periods sufficient to ensure that the data for 2013 can be collected in line with the updated Guidelines?


Q10: Do you agree with our analysis of the impact of the proposals in this Consultation Paper? If not, can you provide any evidence or data that would explain why you disagree or might further inform our analysis of the likely impacts of the proposals?

We agree with the analysis for high earners. In terms of the remuneration benchmarking exercise, this is interesting insofar as it enables the general public to receive information on the development of wages in different business areas of banking and thus enhances transparency. It should be noted that similar documents are already a legal obligation in some member states: in France, for example, all firms with staff of over 300 have to issue a “bilan social” which contains information on remuneration by a classification category (not business area).

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UNI Europa