43. For each staff member that should be included in the gender pay gap calculation in accordance …

For each staff member that should be included in the gender pay gap calculation in accordance with paragraph 40, the investment firm should establish their total gross annual remuneration as the sum of fixed and variable remuneration considering the following:

• a. Non-monetary benefits (e.g. company car, interest-free loans, free company kindergarten, etc.) should be taken into account at their taxed monetary equivalent.
• b. Regular payments into the pension system and health insurance for all staff should not be considered. Discretionary pension benefits should be considered.
• c. The full variable remuneration awarded for all performance periods that ended during the financial year on which the calculation is based should be used, even if they concern performance periods longer than one year.
• d. Guaranteed variable remuneration (sign-on bonus) and severance payments (e.g. where the contract of staff has not yet ended at the end of the financial year) should not be taken into account in the calculation.
• e. For staff who have been working part-time, including for parts of the financial year, or have not been employed for the full financial year or have been on other forms of leave during parts of the year (e.g. unpaid or parental leave), the full annual amount of variable and fixed remuneration should be established on a best effort basis that the staff would have

16 received if they had been paid for the whole financial year on a full-time basis. Investment firms might calculate the amounts by extrapolating the remuneration, e.g. awarded for part-time employment, to the total annual gross remuneration on a full-time annual basis (e.g. the remuneration of staff working on a 50% part-time contract would be multiplied by a factor of 2 to arrive at the annual full-time remuneration).

1. Overview

1.1 References

1.2 Identified Requirements

1.3 Related Standards

2. Identified Requirements

3. Related Standards

• EBA - Published by the European Banking Authority at https://www.eba.europa.eu/