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?

We think that the object, extent and all the definitions are appropriate and sufficiently clear.

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

The section on gender-neutral remuneration policies is sufficiently clear and manages to specify the various elements of staff’s remuneration, that have to reflect experience and skills in fixed remuneration and award staff’s performance in variable remuneration.

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

The section on the remuneration committee is clear and sufficiently detailed.

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

Yes, we think that guidelines concerning the application of requirements within a group context are clear and define correctly how to manage national differences in the implementation of remuneration requirements.

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

Yes, we think that the principle of proportionality is well-defined and that remuneration is proportionate to the risk profile, risk appetite and strategy of the investment firm.

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

Yes, the section on severance payments is sufficiently clear and detailed. In particular we consider appropriate that severance payments are determined and approved as stated in the guidelines, and that such section provides an appropriate compensation for the staff’s member involved.

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?

Provisions on performance criteria included in the guidelines are clear. We think that there aren’t additional performance criteria that need to be introduced.

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

The section on payment in financial instruments seems sufficiently clear and we think that this type of payment has to contribute to the alignment of variable remuneration with investment firm’s performance and risk.

Name of the organization

European Federation of Financial Advisers and Financial Intermediaries (FECIF)