Question 1: Are the guidelines regarding the subject matter, scope, definitions and implementation appropriate and sufficiently clear?
NA
Question 2: Are there any conflicts between the responsibilities assigned by national company law to a specific function of the management body and the responsibilities assigned by the Guidelines, in particular within paragraph 23, to either the management or supervisory function?
NA
Question 3: Are the guidelines in Title I regarding the role of the management body appropriate and sufficiently clear?
See document attached for specific comments.
Question 4: Are the guidelines in Title II regarding the internal governance policy, risk culture and business conduct appropriate and sufficiently clear?
NA
Question 5: Are the guidelines in Title III regarding the principle of proportionality appropriate and sufficiently clear?
NA
Question 6: Are the guidelines in Title IV regarding the internal control framework appropriate and sufficiently clear?
See document attached for specific comments.
Question 7: Are the guidelines in Title V regarding transparency of the organization of the institution appropriate and sufficiently clear?
NA
Question 8: Are the findings and conclusions of the impact assessments appropriate; please provide to the extent possible an estimate of the cost to implement the Guidelines differentiating of one-off and ongoing costs?
