Guidelines on the benchmarking exercises on remuneration practices, the gender pay gap and approved higher ratios under Directive 2013/36/EU

1. Overview

1. Scope of institutions to be included in the benchmarking data exercises

1.1 Scope of institutions for the remuneration data collection

1.2 Scope of institutions for the gender pay gap data collection

1.3 Scope of institutions for the benchmarking of approved higher ratios

2. Submission of benchmarking data to the competent authorities

3. Submission of benchmarking data to the EBA

3.1. List of institutions included in the benchmarking exercises

3.2. Submission of data to the EBA

4. General specifications for the submission of benchmarking data

5. Additional specifications for remuneration data

5.1. Additional specifications for remuneration data under Annex II

5.2. Additional specifications for the remuneration data under

Annex III

6. Additional instructions for the gender pay gap data in Annex IV

7. Data quality

Annex I: General information and information on remuneration of all staff

Name of the institution/group Name Does the institution benefit from the derogation under Article 94 (3)(a) of Directive Yes/no 2013/36/EU at an institutional level? Financial year for which the remuneration is awarded (year N) Year

MB MB Investment Retail Asset Corporate Independent Supervisory Management banking banking management functions control function function functions

All staff in All other subsidiaries staff subject to a specific remuneration framework¹

Number of members

¹ Staff within investment firms, undertakings for collective investment in transferable securities or alternative investment fund manager companies that are subject to a specific remuneration framework under Union acts

Annex II: Additional information on remuneration of identified staff

Name of the institution/group: Name

Financial year for which the remuneration is awarded (year N): Year

Management body Management body Other senior Other identified Supervisory Management management staff function function

Number of beneficiaries of contributions to discretionary pension benefits in year N

Total amount of contributions to discretionary pension benefits (in EUR) in year N (included in other forms of variable remuneration)

Total amount of variable remuneration awarded for multi-year periods under programmes which are not revolved annually (in EUR)

For institutions that do not benefit from the derogation under Article 94(3)(a) of Directive 2013/36/EU at an institution-wide level

Total amount of variable remuneration of identified staff members benefiting from at least one of the derogations under Article 94(3)(b) of Directive 2013/36/EU, based on a low level of variable remuneration

For institutions that do not benefit from the derogation under Article 94(3)(a) of Directive 2013/36/EU at an institution-wide level

Total amount of fixed remuneration of identified staff members benefiting from at least one of the derogations under Article 94(3)(b) of Directive 2013/36/EU, based on a low level of variable remuneration

Annex III: Derogations from the application of requirements to pay out parts of variable remuneration deferred and in instruments under Directive 2013/36/EU (CRD)

Name of the institution/group: Financial year for which the remuneration is awarded (year N): Information on the availability of waivers

Name Year Derogations on a firm-wide Derogations for identified basis under Article 94(3)(a) staff under Article 94(3)(b) CRD CRD

Does the institution apply the derogations regarding the requirement to pay out a part of the variable remuneration deferred and in instruments under Article 94(3)(a) CRD to all its identified staff. If this question has been answered with ‘ yes ’ the information below does not need to be provided. Does the institution apply the derogation from the requirement under Article 94 (1)(l) CRD (pay-out in

Yes/no Yes/no Yes/no

instruments) Where the institution applies the above derogation, but with a lower threshold as implemented under national Threshold law, please indicate the threshold applied in EUR

Headcount Headcount Percentage Percentage EUR EUR EUR EUR EUR EUR Yes/no Yes/no

deferral arrangements) Where the institution applies the above derogation, but with a lower threshold as implemented under national Threshold law, please indicate the threshold applied in EUR

Number of identified staff benefitting from the above derogation Percentage of identified staff benefitting from the above derogation Total remuneration of identified staff benefitting from the above derogation Of which: variable remuneration Of which: fixed remuneration Does the institution apply the derogation from the requirement under Article 94 (1) second paragraph of point (o) (derogations with regard to the pay-out in instruments of discretionary pension benefits) Number of identified staff benefitting from the above derogation Total remuneration of identified staff benefitting from the above derogation Of which: variable remuneration Of which: fixed remuneration

Headcount Headcount Percentage Percentage EUR EUR EUR EUR EUR EUR Yes/no Yes/no Headcount Headcount EUR EUR EUR EUR EUR EUR

Annex IV: Information on the gender pay gap

Representation of staff of different genders per quartile of remuneration level

Representation of male and All male staff in percent of All female staff in percent All male identified staff in All female identified staff in female staff in each all staff of all staff percent based on all percent based on all quartile of remuneration identified staff identified staff

Gender pay pap based on the total gross remuneration

Total gross annual Gender pay gap of all staff, Gender pay gap of all staff, Gender pay gap of Gender pay gap of remuneration level based on median based on mean identified staff, based on identified staff based on median mean

Quartile 1 (low) Percentage (e.g. 42.43%) Percentage Percentage Percentage Quartile 2 (low to medium) Percentage Percentage Percentage Percentage Quartile 3 (medium to high) Percentage Percentage Percentage Percentage Quartile 4 (high) Percentage Percentage Percentage Percentage Total staff/identified staff Percentage Percentage Percentage Percentage

Annex V: Approved higher ratios between variable and fixed remuneration – institutions

Annex VI: Approved higher ratios between variable and fixed remuneration – aggregation by competent authorities

Member State ISO code Year of the collected data yyyy Total number of institutions that have their legal seat within the Member State (additional information to be provided Number below) – e.g. derived from banking statistics Aggregated total number of staff of all institutions within the Member State Number

Aggregated total number of identified staff of institutions within the Member State (where available, otherwise N/A) Number

Aggregated balance sheet total of institutions within the Member State Number

Number of institutions where shareholders have approved a higher ratio that have their legal seat within the Member Number State (additional information to be provided below) Thereof: number of institutions with their legal seat within the Member State that have approved 200% as the Number maximum ratio Aggregated total number of staff of these institutions Number

Aggregated total number of identified staff of these institutions Number

Aggregated balance sheet total of these institutions Number

Aggregated total number of identified staff potentially benefitting from an approved ratio above 100% Number

Aggregated total number of identified staff that have in fact been awarded remuneration that leads to a ratio of variable Number to fixed remuneration above 100% for the financial year

Annex VII – Data quality checks

Institutions and competent authorities should apply the following data quality checks with regard to the tables on remuneration included in the Commission Implementing Regulation (EU) 2021/637¹⁴ .

1.1 References

1.2 Identified Requirements

1.3 Related Standards

2. Identified Requirements

Requirements
Source	Requirement

3. Related Standards

Standards
Source	Requirement

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