Response to consultation on Guidelines on remuneration policies for investment firms

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

NA

Question 2: Is the section on gender neutral remuneration policies sufficiently clear?

Regarding Title I, section 1, paragraph 26 of the Draft Guidelines
We would propose adding a detailed catalogue of criteria for gender-neutral job descriptions as an Annex referring to paragraph 26 of the Draft Guidelines.
Reasons:
We agree that uniform guidelines for job descriptions and positions are needed to implement gender neutral remuneration policies as set out in paragraph 26 of the Draft Guidelines. Nevertheless, we would like to suggest that a detailed catalogue of criteria should be included into the Guidelines on sound remuneration policies, based on which an investment firm has clear guidance for the creation of a gender-neutral job and position description. The aspects mentioned in paragraph 27 of the Draft Guidelines are certainly helpful in this respect. However, we understand that these aspects are only to be used in addition. In this respect, we consider that the inclusion of a detailed catalogue of criteria in the Guidelines should be necessary.

Question 3: Are the sections on the remuneration committee sufficiently clear?

NA

Question 4: Are the guidelines on the application of the requirements in a group context sufficiently clear?

NA

Question 5: Are the guidelines regarding the application of waivers within section 4 sufficiently clear?

NA

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

NA

Question 7: Are the provisions on performance criteria sufficiently clear, which other performance indicators, e.g. regarding the performance of business units or portfolios, are used to determine the variable remuneration of identified staff?

NA

Question 8: Is the section on the pay out in instruments sufficiently clear?

NA

Name of the organization

Verband der Auslandsbanken in Deutschland e.V. - Association of Foreign Banks in Germany