The existing legislation determines that the companies providing investment services will establish, taking into account their scale and activities complexity, employee compensation policies coherent with the promotion of solid and effective risk management measures. The Board of Directors of the company is responsible for approving these remuneration policies.
The primary objective of the establishment of these policies is to avoid taking inconsistent risk management decisions within the company, to always act in the interest of its clients and to prevent conflicts of interest that could arise from variable salary determination policies. It also establishes a remuneration scheme that fits the dedication and responsibilities of the employees to whom it applies, aiming the completion of the strategic objectives of the company within its activities framework.
The responsibilities and functions of the different bodies involved in the establishment, approval, execution and oversight of the policies (Board of Directors, Shareholder General Meeting, Appointments and Remuneration Committee and the Compliance Department) are consistent with the following principles:
The structure of the Compensation Program is based in two parts:
A. Identification of the concerned employees
The policies affect employees within categories where their professional activities impact significantly the risk profile in the company. In particular, it is applied to top management, to employees who assume risks, to those who perform control functions, as well as to every worker that receives a global remuneration included in the same remuneration scale as the previously described and whose professional activities affect in an important manner the risk profile of the entity.
B. Quantification of fixed and variable remuneration
All employees will be clearly informed, since their start, of the criteria that will be used to determine the amount of their retribution, as well as the steps and deadlines of their performance review. The applicable criteria for the performance evaluations will have to be accessible, comprehensive and registered.
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