Guidelines on the benchmarking exercises on remuneration practices and the gender pay gap under Directive (EU) 2019/2034

1. Scope of investment firms subject to the remuneration data collection exercise

2. Scope of investment firms subject to the gender pay gap data collection exercise

3. Submission of data to the competent authorities by investment firms

4. Submission of benchmarking data by competent authorities to the EBA

4.1. Preparation of the data submission to the EBA by competent authorities

4.2. Submission of data to the EBA

5. General specifications for all benchmarking data to be reported

6. Additional specifications for remuneration data

7. Additional specifications for the submission of information on derogations in Annex IV

8. Additional specifications for the submission of the gender pay gap in Annex V

9. Data quality

Name of the investment firm Name Maximum ratio between the variable and fixed remuneration for identified staff set in the investment Percentage firm internal policy Does the investment firm benefit from the waiver under Article 32(4)(a) IFD at an institutional level? Yes/no The investment firm is a subsidiary of an EU parent institution that is subject to Directive 2013/36/EU Yes/no Financial year for which the remuneration is awarded (year N) Year

Number of members

Name of the investment firm Name

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

Name of the investment firm Name Financial year for which the remuneration is awarded (year N) Year

Number of identified

Name of the investment firm Name Financial year for which the remuneration is awarded (year N): Year Information on the availability of waivers Derogation on a firm-wide Derogation for staff basis under Art. 34(4)(a) IFD under Art. 34(4)(b) IFD Does the investment firm apply the derogations regarding the requirement to pay out a part of the variable Yes/no remuneration deferred and in instruments under Article 34(4)(a) IFD to all its identified staff? If this has been answered with ‘ yes ’ the information below does not need to be provided. Does the investment firm apply the derogation from the requirement under Article 32 (1)(j) IFD (pay-out in Yes/no Yes/no instruments)? Where the investment firm 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 Headcount Headcount Percentage of identified staff benefitting from the above derogation Percentage Percentage Total remuneration of identified staff benefitting from the above derogation EUR EUR Of which: variable remuneration EUR EUR Of which: fixed remuneration EUR EUR Does the investment firm apply the derogation from the requirement under Article 32 (1)(l) IFD (pay-out under Yes/no Yes/no deferral arrangements)? Where the investment firm 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 Headcount Headcount Percentage of identified staff benefitting from the above derogation Percentage Percentage Total remuneration of identified staff benefitting from the above derogation EUR EUR Of which: variable remuneration EUR EUR Of which: fixed remuneration EUR EUR Does the investment firm apply the derogation from the requirement under Article 32 (1), third subparagraph of Yes/no Yes/no paragraph 3 (derogations with regard to the pay-out in instruments of discretionary pension benefits)? Number of identified staff benefitting from the above derogation Headcount Headcount Total remuneration of identified staff benefitting from the above derogation EUR EUR Of which: variable remuneration EUR EUR Of which: fixed remuneration EUR EUR

25

Annex V – Information on the gender pay gap

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

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

26

Investment firms and competent authorities should apply the following data quality checks with regard to Annex II and Annex III.

Annex II:

Row Data quality check

The number of staff reported under the management body columns should be 1 integral numbers.

The total fixed remuneration should be the sum of rows 4 to 10; where identified 3 staff are reported the amount should be > zero.

The total variable remuneration should be the sum of the rows 12, 14, 16, 18, 11 20, 22 and 24.

The total variable remuneration should not be lower than the sum of guaranteed 10 variable remuneration and severance payments in rows 31 and 33.

The sum of deferred remuneration in rows 13, 15, 17, 19, 21, 23 and 25 should - not be higher than the value in row 11.

Ratio of deferred remuneration: the sum of deferred remuneration in rows 13, 15, 17, 19, 21, 23 and 25 should be higher than or equal to 0.4 times the value in row 11 after the deduction the values in rows 31, 34 and 42 (>=0.4 x row11-31-34-42).

Investment firms should consider that this simplified validation rule is for benchmarking purposes only and is not a validation of the compliance with the remuneration requirements regarding guaranteed variable remuneration and - severance payments, i.e. while the full amounts are deducted, parts of the amounts are possibly subject to the requirement to pay out parts of the variable remuneration under deferral arrangements.

This validation rule does not apply to investment firms where all identified staff benefit from the derogation to the requirement to pay out parts of the variable remuneration under deferral arrangements under Article 32(4)(a) of Directive (EU) 2019/2034. Payout in instruments: the sum of rows 14, 16, 18, 2 and 22 should be higher than or equal to 0.5 times the value in row 11 after deducting the values in rows 31, 34 and 42 (>=0.5x(row 11-31-34-42)).

Investment firms should bear in mind that this simplified validation rule is for benchmarking purposes only and is not a validation of compliance with the remuneration requirements regarding guaranteed variable remuneration and

• - severance payments, i.e. while the full amounts are deducted, parts of the amounts are possibly subject to the requirement to pay out parts of the variable remuneration in instruments.

This validation rule does not apply to investment firms where all identified staff benefit from the derogation from the requirement to pay out parts of the variable remuneration in instruments under Article 32(4)(a) of Directive (EU) 2019/2034. Annex III:

Data quality check

The number of members of the ‘management body’ should equal the number included in row 1 of Annex II.

The sum of staff reported under ‘other senior management’ should be equal to the number reported in row 2 in Annex II for this category.

The sum of sta ff reported under ‘other identified staff’ should be equal to the number reported in row 2 in Annex II for this category.

The number of identified staff for each business area should equal the sum of the number of ‘other senior management’ and the number of ‘other identified staff’ .

The sum of the total remuneration across all business areas should be equal to the sum of the values in row 3 and row 11 in Annex II across all categories of staff.

The sum of the variable remuneration across all business areas should be equal to the sum of the values in row 11 in Annex II across all categories of staff.

The sum of the fixed remuneration across all business areas should be equal to the sum of the values in row 3 of Annex II across all categories of staff.