Remuneration Policy. The Board of Directors of Swedbank Robur Fonder AB ( Robur ) Date of adoption (replaces ) Applies to

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1 Remuneration Policy Adopted by The Board of Directors of Swedbank Robur Fonder AB ( Robur ) Date of adoption (replaces ) Applies to Robur Local Framework Owner Head of HR at Robur Responsible for implementation Robur s CEO Distribution Local Framework section intranet Language version Information class Basis English Public S-FSA regulatory code FFFS 2013:9 och 2013:10 1. Purpose and background 1.1 The objective of this Policy is to set aligned and overarching principles and practices for the remuneration to the employees of Robur and more detailed regulations regarding Special Regulated Staff (SRS) with the alignment of the company s business strategy and the relevant fund s investment strategy. As further detailed in this Policy, Robur applies a total remuneration approach to compensation which includes fixed and Variable Remuneration, pension schemes and other benefits. Robur acknowledges the importance of well balanced but different remuneration packages derived from business and local market needs, as well as compensation being consistent with and promoting sound and effective risk management. 1.2 Robur is committed to maintaining robust remuneration arrangements that are in accordance with regulatory requirements including the regulations of the Swedish Financial Supervisory Authority. This policy provides the overarching framework for Robur in carrying out all efforts in this area. Further, Robur is committed to fulfilling applicable requirements on transparency in relation to its remuneration arrangements. 1.3 This Policy covers Remuneration to all employees of Robur. 1.4 Terms related to this Policy are defined in section Remuneration philosophy Total Remuneration approach 2.1 Robur offers competitive but not market leading compensation that is derived from business and local market need and which is set independently of gender, transgender identity or expression, ethnicity, religion or other belief, disability, sexual orientation or age. 2.2 Robur applies a total remuneration approach which aims to attract and retain people with the ability, experience and skills to deliver on Robur s strategy;

2 create an alignment between the rewards and the risk exposure of unit holders, shareholders and employees, counteract excessive risk-taking and incentivise employees to deliver sustainable performance, of Robur and the funds managed by Robur at any given time, that is consistent with strategic goals as well as healthy and effective risk management, deliver remuneration that is affordable and appropriate in terms of value allocated to the unit holders, shareholders and employees, and encourage behaviour consistent with Robur s values and that reflect Robur s dedication to service its customers. 2.3 Remuneration for his/her subordinates is a decision made by each manager and when needed, after consultation with HR. Any such decision must in turn be approved by the manager s own superior (the so-called grandfather principle) and HR following applicable governance structure in Robur. Fixed remuneration 2.4 Fixed remuneration constitutes the primary component of Remuneration. It reflects the nature and responsibility of the position held, individual employee performance and market conditions. 2.5 Fixed remuneration during a term of notice and any severance pay to the CEO, CEO s direct reports and employees with responsibilities within Asset Management must not exceed an amount corresponding to the sum of the current agreed fixed salary at the time of notice including benefits in accordance with the employment agreement during the first 12 months and thereafter the agreed fixed salary for the following 12 months. The size of the severance pay should never contradict the principles stated in this policy. Variable Remuneration 2.6 Variable Remuneration is a component of Remuneration which aims to incentivise particular behaviours and desired results; create an alignment between the rewards and risk exposure to those of the unit holders, shareholders, and employees; and provide motivation and foster a performance driven culture in Robur. 2.7 Variable Remuneration may only be granted as part of Robur s Variable Remuneration programs that are approved by the Board or otherwise explicitly stated in this Policy. 2.8 Guaranteed Variable Remuneration shall always comply with the Group s remuneration philosophy and the specific requirements set out in this Policy, and should always be approved by Swedbank GEC Remco. It is only allowed in connection with new employment and if exceptional reasons apply in the form of sign-on remuneration and shall only be paid during the first year of employment.

3 2.9 Robur does not apply Variable Remuneration containing discretionary pension benefits Variable Remuneration paid out on the basis of information which later turned out to be clearly erroneous or the result of fraudulent activities, must be reclaimable for Robur. Head of HR must ensure that there are procedures for how managers are to agree on such terms with the employee if said terms are not specified in the general terms for awarded Variable Remuneration. Balance between Fixed Remuneration and Variable Remuneration 2.11 If Remuneration includes a variable portion, there shall be an appropriate balance between the fixed and the variable portions. The fixed portion of the Remuneration must account for a sufficiently large portion of the total Remuneration so that it is possible to set any Variable Remuneration to zero Variable pay is maximized to 12 times fixed monthly salary for all staff categories if a lower ratio is not required by applicable Regulations. Severance payment and gratuities 2.13 Remuneration paid out in connection with the termination of employment must be in proportion to the employee s performance during the term of employment and must not reward unsound risk-taking Ancillary payments or benefits, such as gratuities, that are part of a general, nondiscretionary recognition program and which pose no incentive effects in terms of risk assumption may be awarded subject to prior approval from Robur s Remuneration Committee. Risk analysis 2.15 When adopting the above Remuneration approach and this Policy, the following aspects have been considered: (1) Robur conducts extensive asset management operations directed to both private and corporate clients. (2) Sound risk-taking is part of Robur s business strategy. (3) Competitive Remuneration systems are an important part of Robur s efforts to attract, retain, and motivate the most skilled staff possible. On one hand, there is a risk that Variable Remuneration for employees leads to disproportionate risk-taking. On the other hand, Variable Remuneration serves as an important incentive to realise the business strategy of Robur, and to stimulate employees to make efforts to strengthen the long-term value of Robur and the funds managed by Robur. 3. Variable Remuneration programs 3.1 The Board annually decides on the Variable Remuneration programs and the detailed terms that will be applied as well as the basis for participation in such programs. No other Variable Remuneration arrangements are allowed if not explicitly stated in this Policy. The programs shall comply with the Remuneration

4 philosophy reflected in section 2 above and the specific requirements set out below. A decision on a Variable Remuneration program will always be preceded by a risk analysis provided by the Risk Functions (Operational Risk and Investor Risk). Overall performance criteria, risk, and capital 3.2 The total Variable Remuneration payable by Robur must not be of such size that it may affect the Robur s ability to maintain a sound capital base or, as needed, to reinforce the capital base. Taken into account the long term interests of the unit holders, other stake holders and the public. The Chief Financial Officer will provide an annual assessment to this effect in conjunction with the adoption of Variable Remuneration programs and the pay-out thereof. The assessment of the yearly result of Robur should be based on Robur s risk-adjusted profit, taking into consideration both current and future risks. 3.3 Variable Remuneration will be based on relevant, predetermined and measurable criteria, set with the purpose of increasing the long-term value of Robur and the funds managed by Robur at any given time for the unit holders. Consequently, it shall be considered how Remuneration may affect the profit of Robur and the funds managed by Robur, as well as risks, at any given time from a long-term perspective. The term measurable means that it shall be possible to evaluate the degree to which the criteria have been fulfilled afterwards. A multiple-year perspective shall be applied to ensure long term sustainability of profits considering the recommended holding period for the funds, the underlying business cycles and risks at the time of pay-out also. Individual performance criteria 3.4 On an individual employee basis, Variable Remuneration will be based on employee s performance assessed against performance criteria set at the beginning of each calendar year. The performance criteria on which the Variable Remuneration decision is based must be specified and documented as part of the Performance Development (PD) process. For each eligible employee, a maximum amount of Variable Remuneration shall be set at the beginning of each calendar year. As Robur strives for a value driven corporate culture, the personal performance criteria will include an element of Living the Values. Lack of compliance with external or internal regulation or deficiencies in risk management capabilities are such circumstances that will be considered as lack of performance in relation to Living the Values. Combined basis for Variable Remuneration 3.5 The overall performance criteria and the individual performance criteria shall be construed and applied in such a way that Variable Remuneration is based on Robur s and, in the case of SRS, the funds managed by Robur s at any given time overall performance as well as the individual s performance. Control functions staff

5 3.6 Any Variable Remuneration to employees in control functions will be determined based on objectives set in the respective Control function, independently of the earnings in the business areas they oversee. Variable Remuneration composition and deferrals 3.7 For employees who are not SRS, Variable Remuneration shall consist of shares in Swedbank AB (publ) or instruments tied to such shares and are deferred for at least three years. 3.8 For employees who are SRS, at least 40 percent of each employee s Variable Remuneration shall be deferred over a period which is appropriate in view of the holding period recommended to the investors of the fund. The deferment period shall be at least 3 years. 3.9 For employees who are SRS and whose Variable Remuneration amounts to a Particularly High Amount, at least 60 percent of each employee s Variable Remuneration shall be deferred over a period which is appropriate in view of the holding period recommended to the investors of the fund. The deferment period shall be at least 3 years The Particularly High Amount will be decided by the Board in retrospect of the relevant financial year when the aggregate amount of Variable Remuneration is known as well as individual allocations For employees who are SRS, at least 50 percent each employee s Variable Remuneration shall consist of units of the fund or funds concerned. This shall be applied to both the deferred portion of the Variable Remuneration and the portion not deferred. The instruments referred to in this section shall be subject to a one year retention period following the transfer of rights of ownership of the instrument to the employee For employees who are SRS, any Variable Remuneration pay-out will be divided in into 50% in cash and 50% in fund units. The deferral period will mirror the holding period recommended to investors (at least 3 years), meaning 5 years for most employees and 3 years for some employees]. Each payout will be divided in into 50% in cash and 50% in fund units. 60% will be paid directly after the performance year and 40% after the deferral period. Fund units and cash deferred 5 years will be paid out pro-rata, meaning 8% each year 1-5 years after the performance year. Fund units shall be subject to a one year retention period following the transfer of rights of ownership of the instrument to the employee. Delivery and cancellation 3.13 Variable Remuneration will only be delivered provided that delivery is justified considering:

6 (a) the financial health of Robur, the funds managed by Robur at any given time and the relevant business unit where the employee works. (b) the relevant employee s performance against the personal performance criteria referred to above in section 3.4. Further, deferred Variable Remuneration may be cancelled during the deferment period for the aforementioned reasons. Special Regulated Staff (SRS) 3.14 All SRS within Robur shall be identified on an individual basis. The categorization process shall be in line with the principles set out in Definitions. SRS shall be made aware of the implications of their status. It is the responsibility of the Head of HR to conduct the annual process to identify and document employees that have a material impact of Robur s, and/or the funds managed by Robur s, risk profiles. The categorization process,the assessment and identification of SRS shall be documented in writing. The Head of HR maintains an up-to-date list of all SRS Any interpretation of the principles in section 6 that reasonably could be interpreted as a deviation from those principles shall be documented in writing by the relevant employee s manager and approved by the manager s manager and Robur Remuneration Committee. Other 3.16 Employees may not use personal risk hedging strategies or insurances that aims to reduce or eliminate the effects of the deferred Variable Remuneration being adjusted or cancelled. 4. Governance and control etc. The Board and the Remuneration committee 4.1 The Board has the overall responsibility to ensure that there are adequate routines in place for this Policy to be implemented and enforced. The Board has appointed a Robur Remuneration Committee to prepare decision basis for the Board s decisions. The decision basis shall take into account the long term interests of the unit holders, other stake holders and the public. The decision basis should minimum include; (a) Fixed remuneration to the CEO and deputy CEO. (b) Fixed renumeration to the direct reports of the CEO, (c) Fixed remuneration to employees who have overall responsibility for any of the internal control functions. (d) Measures to be taken in order to follow up on the implementation of the Remuneration Policy.

7 (e) The Board shall review the appointment of the Remuneration Committee annually. The Remuneration Committee is a preparatory body that reports to the Board and submits recommendations to the Board for approval. The Remuneration Committee consists of members of the Board and shall have the sufficient knowledge and experience in issues regarding remuneration and risk management. 4.2 The Board has appointed Swedbank AB Remuneration Committee to review and recommend to the Robur Remuneration Committee for its approval inter alia: (a) Total amount of Variable Remuneration in any financial year. (b) Variable Remuneration programs and the implementation thereof such as general principles for participation, quarterly accruals, disbursement and potential cancellation of deferred Variable Remuneration (c) Maximum ratio of the variable components to the fixed components for all categories of staff eligible for Variable Remuneration and any exceptions to this ratio. (d) Particularly High Amount or any amendments there of (e) Amendments or exceptions to this Policy. The Board has appointed the Swedbank AB Remuneration Committee to (i) assist the Robur Remuneration Committee in fulfilling its responsibility to ensure that Robur maintains, implements and provides proper disclosure of (a) formalized processes for decisions on remuneration of top executives and (b) a remuneration policy which is consistent with and promotes effective risk management and does not encourage excessive risk-taking, and (ii) review and prepare for decision to Robur Remuneration Committee that are to be decided by the Board. Managerial responsibilities 4.4 Each manager is responsible for setting and following-up on individual performance criteria set in the PD-process for his/her direct reports that comply with sections above. Further, each responsible manager shall ensure that, within his/her area of responsibility, all employees receive information about the criteria which form a basis for their Remuneration and about how their respective performance is assessed. 4.5 The Head of HR is responsible for leading the work to set and follow up on the implementation of common processes and standards. This includes the provision of structure in relation to setting Individual Performance Criteria. Furthermore it s the responsibility of the Head of HR to ensure that information of how Robur s Remuneration Policy and Remuneration systems comply with applicable legislation. 4.6 The Head of HR is responsible for leading the work to set and follow up on the implementation of common processes and standards to implement section 3 of this

8 Policy. This includes the development of Variable Remuneration programs (for Board approval) and the provision of a process to implement such programs. Measures to avoid conflicts of Interest 4.7 The Variable Remuneration program is designed, as far as possible, to avoid conflicts of interest. Depending on the structure of the Variable Remuneration portfolio managers who manage serveral funds may choose to prioritise one fund over another. To mitigate this, each participant is evalutated on all of its management assigments including Discretionary assignments. The Variable Remuneration is a component which aims to incentivise particular behaviors and desired results, create an alignment with unit holders. Portfolio managers may choose to either increase or decrease the risk level in the fund relative to his or his/her risk mandate to affect the outcome of the Variable Remuneration. Besides the continuous monitoring of the risk level, Investor Risk review the risk utilization on a yearly basis to verify that the interests are aligned i.e. the unit holders and the portfolio manager s. The Variable Remuneration is based on the participant s performance assessed against performance criteria set at the beginning of each calendar year. The performance criteria on which the Variable Remuneration decision is based must be specified and documented as part of the PD-process as mentioned section 3.4. The structure of Variable Remuneration program and outcome for the participants are followed up and monitored, among other things, from a conflicts of interest perspective. Control function reviews 4.8 A control function will, at least, annually review compliance with this Policy and ensure that an analysis of the terms and conditions from a compliance perspective is performed in conjunction with the adoption of a Variable Remuneration program. The control function shall report the outcome of the reviews to the Board. 4.9 The Risk Function (Operational Risk and Investor Risk) will ensure that a risk analysis is performed in conjunction with the annual adoption of this Policy and a Variable Remuneration program. The Risk Functions, is responsible for assessing risk management capabilities in relation to those employees who are part of such Variable Remuneration programs that are not directed to all employees. The Risk Functions will also review compliance with sections and 3.13 as well as pay out statements in relation to the top earners of Variable Remuneration The control functions shall be independent from the business units they oversee and shall be ensured appropriate authority and resources to monitor and control the risks associated with Robur s remuneration structure. 5. General Provisions 5.1 This Policy must be revised on a regular basis at the Board's discretion.

9 6. Definitions In this Policy, the following concepts, terms and expressions are defined as stated below. Policy: Swedbank Robur Fonder AB Remuneration Policy Remuneration: All remuneration and benefits to an employee (e.g., cash salary, other cash remunerations, shares or share-related instruments, fund units or instruments whose performance is correlated with the performance of the portfolios managed, pension provisions, severance pay and car benefits). The Group: Swedbank AB (publ) and its Subsidiaries at any given time. The Board: The board of Swedbank Robur Fonder AB Control functions: Group Risk Control functions, the Group Compliance function, the Group Internal Audit function or where applicable the equivalent Robur control function. Special Regulated Staff (SRS) Senior management (as defined in FFFS 2013:96 Chapter 1, 9 section 30) and employees in the following categories of staff: 1 employees in strategic management positions, 2 employees responsible for control functions, 3 risk takers, and 4 employees whose total remuneration is equal to or exceeds the total remuneration to any of the members of senior management. Employees under the categorize 2-4 can be exempt from the definition SRS, in accordance to FFFS 2013:9, Chapter 8 a. 5, if Robur can document and motivate that the employees professional activities does not have a material impact on the Robur s risk profile or the risk profiles of the funds that Robur manages. Variable Remuneration: Remuneration that is not fixed in advance to a particular amount or size. Allowances that are not (i) permanent and linked to the position/its responsibility (ii) predetermined, documented and transparent (iii) non-discretionary and non-revocable, are defined as Variable Remuneration. In this context, Variable Remuneration does not include Commission-based Remuneration not liked to future risk assumptions that may alter an fund manager s or a fund s profit and loss statement or balance sheet. Particularly High Amount: The amount that is decided by the Board in connection with the establishment of the outcome of Variable Remuneration for a particular year. The assessment shall be made in relation to other compensation in company, the remuneration levels that have been common in the company in the past and other circumstances.