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European Federation of Financial Advisers and Financial Intermediaries (FECIF)

We think that the object, extent and all the definitions are appropriate and 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.
The section on the remuneration committee is clear and sufficiently detailed.
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.
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.
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.
Provisions on performance criteria included in the guidelines are clear. We think that there aren’t additional performance criteria that need to be introduced.
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.
European Federation of Financial Advisers and Financial Intermediaries (FECIF)