Remuneration Policy

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:

• Compliance with adequate and efficient risk management, and does not offer incentives towards assuming risks above the company’s pre-established levels.
• Compliance with the company’s strategy, its objectives, values and long term interests, including procedures to avoid possible conflicts of interests.
• Acknowledgment of market trends. Positioning towards these must comply with the company’s strategic approach.
• The retribution assigned to each employee is defined based on his position, under a homogenous treatment to those with similar responsibilities and functions.
• The retribution of the control functions is independent of the results generated by the business units supervised.

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

• The fixed remuneration will primarily reflect the relevant professional experience and the responsibility within the organization.
• The variable remuneration is subject to a series of generic or specific objectives and, generally, is based in a series of principles, of which the most important are listed below, but not limited to:
  • The total variable remuneration does not limit the entity’s capacity to strengthen the solidity of its capital base and undermine its solvency.
  • The variable remuneration reflects a sustainable performance within the risk policies, as well as a performance superior than required in order to fulfill the stipulated in the description of functions as part of the working conditions.
  • The variable salary, within a multiannual scheme, is determined taking into account individual results from management, the development and positioning of the business on the corporate level; as well as the employee’s contribution to the progress and proper functioning of the company.
  • The variable components of the remuneration are sufficiently flexible to allow its modulation; to the extent it is possible to suppress the variable remuneration in case the objectives to which it is linked are not achieved.
  • In any case the variable remuneration is guaranteed.
  • It will be possible to determine that a substantial part is deferred during a period of time not inferior to three and maximum of five years.

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.