13. Remuneration policy for identified staff

Investment firms must ensure that the remuneration policy for identified staff complies with all principles set out in Articles 30 and 32 and, where applicable, Article 31 of Directive (EU) 2019/2034 and is gender neutral.

The appropriate ratio between the variable and fixed remuneration components for identified staff should be set independent of any potential future ex post risk adjustments or fluctuation in the price of instruments.

Investment firms should implement, for different categories of identified staff, specific remuneration policies and risk alignment mechanisms as appropriate to ensure that the impact of the category of identified staff on the investment firm’s risk profile is appropriately aligned with their remuneration.

Where investment firms consider paying out less than 100% of the fixed component of remuneration in cash, this decision should be well reasoned and approved as part of the remuneration policy.

Where an investment firm in the legal form of a stock corporation and in particular a listed investment firm applies a shareholding requirement to some categories of identified staff in order to achieve a better alignment of the incentives provided to staff with the risk profile of the investment firm in the long term, the amount should be clearly documented in the investment firm’s policies. When a shareholding requirement is applied, staff should hold a certain number of shares or nominal amount of shares as long as they are employed in the same position or a position of equal or higher seniority.