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Controlled remuneration policy principles

The regulation for a sound remuneration policy at financial institutions (hereinafter, “the Regulation”) took effect on 16 December 2010. The Regulation sets out principles that the remuneration policy and culture regarding remuneration at a financial institution must meet in order to ensure that risks are controlled.

The Regulation covers all employees at financial institutions. Under the Regulation, financial institutions are obliged to identify the employees whose activities can materially influence the risk profile of the company (known as the 'identified staff'). This in any case includes the executive board, senior management and control positions. Positions and activities at business units can however also materially affect the risk profile.

Specific measures must be taken with regard to employees in these positions and involved in these activities to manage the risks associated with variable payments, in the form of requirements with regard to performance criteria, the conditional allocation of variable pay and the form of payment. Since not every position or activity has the same effect on the risk profile, the specific requirements can be applied proportionally.

The remuneration policy of a financial institution should contribute to the sound and effective management of risk, and should not form an incentive to assume risks that are not acceptable to the company. In addition, the remuneration policy should be consistent with the business strategy, objectives, values and long-term interests of the financial institution, and should include measures designed to avoid conflicts of interest. The basic principle should be that the employee is rewarded for their actual performance over the longer term.

In accordance with the principles of the Code, the Banking Code, and Principles for a controlled remuneration policy, BinckBank revised her Remuneration policy 2010 for the executive board.