AFG- Association Française de la Gestion Financière

Please refer to attached document. We do not agree with the definition of Long term incentive plans". Deferrals are different from stock option plans, and generally a deferral has one award date and several vesting dates, not several award dates."
Please refer to attached document. We note para 14 is simple and efficient. A definition of corporate functions (mentioned in para 14) would help.
Please refer to attached document. Too much information to be potentially provided to shareholders (para 34), as Remco and board have more efficient oversight role for technical and confidential incentive structures.
Please refer to attached document. Para 57 is unclear as to which functions are concerned.
Please refer to attached document. Notably for proportionality, and for paragraphs 80 and 81.
Please refer to attached document. There is too much complexity and costly paperwork and processes, notably on identification of staff. It gives the impression that busineses are static entities, which they are not. We welcome para 104.
Please refer to attached document. CET1 considerations not relevant for asset management entities.
Please refer to attached document. Vesting word seems ignored, and award used instead, which is confusing.
Please refer to attached document. Not applicable to asset management companies, which have no capping of variable remuneration.
Please refer to attached document. Para 126 (ratio) not applicable to asset management entities.
Please refer to attached document.
Please refer to attached document. AFG considers newly required compliance checks on personal accounts are additionnal complexity and operational burden, of little value vs. the former declarative approach.
Please refer to attached document. AFG considers the differentiated ratio per business" approach proposed in the GL, is excessively burdensome and complex, and does not reflect day-to-day business operational requirements in a financial conglomerate."
Please refer to attached document. AFG is concerned (para 223) that too many years of records be required, with excessive granularity of information, proving again, burdensome and administratively costly, with overall little value added.
Please refer to attached document.
Please refer to attached document. Overall, this section seems too prescriptive (eg shares and no cash-indexed instruments for listed companies), and does not allow for sufficient freedom of business, unnecessarily restraining ability to be efficient. Loss absorbency concept is a welcome criteria (para 249).
Please refer to attached document. Overall, this section seems too prescriptive, and does not allow for sufficient freedom of business, unnecessarily restraining ability to be efficient. Retention is often less efficient than deferral, and we would prefer maximising deferral. Pls see our proposal for Para 257 in the attached document.
Please refer to attached document. AFG points out the high difficulty to implement claw back in French labour law. A time limit for claw back and malus implementation is welcome (para 269). Back testing approach is a welcome one (para 268).
Please refer to attached document.
Please refer to attached document. Again, excessive administrative work (e.g. very detailed and complex disclosure requirements) is costly and weighs on competitiveness, and too detailed information will severely hinder it as well. More thought is needed on what synthetic and relevant information, shareholders should really have to make well-informed judgements. AFG believes this is more about quality than quantity.
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