9.1 Guaranteed variable remuneration

Guaranteed variable remuneration can take several forms such as a ‘guaranteed bonus‘, ‘welcome bonus‘, ‘sign-on bonus‘, ‘minimum bonus‘ etc., and can be awarded either in cash or in instruments.

When awarding guaranteed variable remuneration in accordance with Article 32(1)(e) of Directive (EU) 2019/2034 when hiring new staff, investment firms are not permitted to guarantee variable remuneration for longer than the first year of employment. Guaranteed variable remuneration is exceptional and can only occur where the investment firm has a strong capital base in line with these guidelines.

Investment firms should only award once to the same single staff member guaranteed variable remuneration. This requirement should also apply at a consolidated level and includes situations where staff receive a new contract from the same investment firm or another firm within the scope of consolidation.

As part of the arrangements guaranteeing this part of variable remuneration, investment firms may decide to not apply the requirements on malus and clawback arrangements to guaranteed variable remuneration. Investment firms may pay out the full amount in non-deferred cash.