Response to consultation Paper on Draft Guidelines on sound remuneration policies under Directive 2013/36/EU

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Question 1: Are the amendments to the subject matter, scope and definitions appropriate and sufficiently clear?

Please refer to the attached document.

Question 2: Are the amendments regarding gender neutral remuneration policies sufficiently clear?

Please see the position paper attached.

Question 3: Are the guidelines on the application of the requirements in a group context sufficiently clear?

Please refer to the attached document. .

Question 4: Are the guidelines regarding the application of waivers within section 4 sufficiently clear?

Please refer to the attached document.

Question 5: Is the section 8.4 on retention bonuses sufficiently clear?

Please refer to the attached document.

Question 6: Is the amended section 9 on severance payments sufficiently clear?

Please refer to the attached document.

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Name of the organization

European Association of Co-operative Banks (EACB)