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OP-Pohjola Group

The subject matter and scope are sufficiently clear
The scope and process are sufficiently clear.
The scope is sufficiently clear.
The information to be submitted is sufficiently clear.
We strongly propose introduction of a glossary providing clear and understandable definitions and compilations for each reporting measure and category to ensure that the data gathered from each institution/group is comparable. We strongly encourage that, before introduction of the revised template, each term and metric used in the templates is clearly defined to promote validity and comparability of the data collected.

We note that references to terminology in the annex’s footnotes are somewhat faulty, and find them insufficient and burdensome to understand, as they only provide references to legislation, if any.
For example
 Term independent control functions is not defined anywhere in the document.
 Definitions and compilations for measures Headcount and FTE are missing
 Definition of the members of the management body in its supervisory function is different between Annex 1 and Annex 2, and is not sufficiently clear for an institution to be able to apply it.
 Definition of the members of the management body in its management function is different between Annex 1 and Annex 2, and is not sufficiently clear for an institution to be able to apply it.

We strongly propose not to disclose remuneration for the non-executive management body members, as they are not part of the salaried staff, and hence should not be included in the data gathering exercise. We propose that this is clarified throughout the templates, and it is clearly mentioned that scope of the reporting is staff only.
Clarification and clear examples on whether or not the data should be reported on the paid-basis (i.e. remuneration actually paid during the year of reporting) or on the earnings-basis (i.e. remuneration earned during the year of reporting, but not fully paid to the individual). The term awarded is not sufficiently clear, and we strongly propose that concrete numerical examples are given to ensure common interpretation of the term award.
Due to the RTS on identified staff also being under revision, and its date of application to date remaining unknown, it should be clearly stated that for the remuneration benchmarking exercise the identified staff should be determined according to the old standards.
The template is appropriate and sufficiently clear.
Clarification and clear examples on whether or not the data should be reported on the paid-basis (i.e. remuneration actually paid during the year of reporting) or on the earnings-basis (i.e. remuneration earned during the year of reporting, but not fully paid to the individual). The term awarded is not sufficiently clear, and we strongly propose that concrete numerical examples are given to ensure common interpretation of the term award.
The reporting period and the currency conversion are sufficiently clear.
The example given in point 6.5. is not clear, and we propose clarifying what is meant by “full amounts in euro”.
The time periods are insufficient considering that the revised guidelines shall apply from 1 July 2014, leaving only two months of July and August for the gathering of the data. The indicated two months are insufficient and challenging as they occur during the summer vacation season as well as overlap with budgeting processes. The deadline is proposed to be postponed to 31 October 2014, or later.
Due to the RTS on identified staff also being under revision, and its date of application to date remaining unknown, it should be clearly stated that for the remuneration benchmarking exercise the identified staff should be determined according to the old standards. This should be the case regardless of whether or not the deadline of the remuneration benchmarking exercise is postponed to the suggested 31 October 2014.
We also note that, should the deadline for the submission of data be postponed to 31 October 2014, the final guidelines should be available from 1 June 2014 the latest, in order to have sufficient time to react and apply the guidelines to data collection. Should the deadline for submission not be postponed, and the final guidelines be published later than 1 June 2014, meeting the proposed deadline will not be possible.
We do agree with the analysis, and would like to underline that the increased granularity of the data collected significantly increases costs of the data collection process for each institution.
We also note that the data collection process does not have any value adding features to the institutions themselves, and thus only serves the purposes of the authorities. We propose to develop the processes in closer cooperation with the institutions in the future to better incorporate the data collection exercises with the institutions' remuneration planning, and thus becoming a value adding exercises.
Laura Rotkin
O