Legal references and instructions

Row number

Explanation

(a)

Information relating to the bodies that oversee remuneration. Disclosures shall include:

(b)

Information relating to the design and structure of the remuneration system for identified staff. Disclosures shall include:

(c)

Description of the ways in which current and future risks are taken into account in the remuneration processes

Disclosures shall include an overview of the key risks, their measurement and how these measures affect remuneration.

(d)

The ratios between fixed and variable remuneration set in accordance with point (g) of Article 94(1) of Directive (EU) 2013/36(‘CRD’) (1)

(e)

Description of the ways in which the institution seeks to link performance during a performance measurement period with levels of remuneration

Disclosures shall include:

(f)

Description of the ways in which the institution seeks to adjust remuneration to take account of long-term performance

Disclosures shall include:

(g)

The description of the main parameters and rationale for any variable components scheme and any other non-cash benefit, as referred to in point (f) of Article 450(1) CRR. Disclosures shall include:

(h)

Upon demand from the relevant Member State or competent authority, the total remuneration for each member of the management body or senior management, as referred to in point (j) of Article 450(1) CRR

(i)

Information on whether the institution benefits from a derogation laid down in Article 94(3) CRD, as referred to in point (k) of Article 450(1) CRR

For the purposes of this point, institutions that benefit from such a derogation shall indicate whether this is on the basis of point (a) and/or point (b) of Article 94(3) CRD. They shall also indicate which of the remuneration requirements they apply the derogation(s), (i.e., point (l) and/or (m) and/or (o) of Article 94(1) CRD), the number of staff members that benefit from the derogation(s) and their total remuneration, split into fixed and variable remuneration.

(j)

Large institutions shall disclose the quantitative information on the remuneration of their collective management body, differentiating between executive and non-executive members, as referred to in Article 450(2) CRR.

Legal references and instructions

Row number

Explanation

1 and 9

Number of identified staff

The number of staff whose professional activities have a material impact on the institutions’ risk profile in accordance with Article 92 CRD and the Commission Delegated Regulation on identified staff (1) implementing Article 94(2) CRD (identified staff) and are beneficiaries of the remuneration components listed in this template. It shall be calculated using the FTE (full time equivalent) approach for identified staff other than members of the management body where numbers shall be disclosed as headcount.

2

Total fixed remuneration

Sum of amounts in rows 3 to 7 of this template

3

Of which: cash-based

The amount of cash-based remuneration within the fixed remuneration

EU-4a

Of which: shares or equivalent ownership interests

The sum of the amounts of shares or equivalent ownership interests, subject to the legal structure of the institution concerned referred to in point (l)(i) of Article 94(1) CRD, within the fixed remuneration.

5

Of which: share-linked instruments or equivalent non-cash instruments

The sum of the amounts of share-linked instruments or equivalent non-cash instruments referred to in point (l)(i) of Article 94(1) CRD, within the fixed remuneration

EU-5x

Of which: other instruments

The amount of other instruments referred to in point (l)(ii) of Article 94(1) CRD, within the fixed remuneration

7

Of which: other forms

The amounts of fixed remuneration awarded for the financial year that are other than disclosed in other rows under the total fixed remuneration heading

This could include proportionate regular pension contributions, or benefits (where such benefits are without consideration of any performance criteria), referred to in recital (64) CRD or other forms of remuneration like car allowances.

10

Total variable remuneration

Sum of amounts in rows 11, EU-13a, EU-13b, EU-14x and 15 of this template

The sum of all remuneration components that are not fixed remuneration that is disclosed in row 2 of this template, including guaranteed variable and severance payments awarded during that year.

11

Of which: cash-based

The amount of cash-based remuneration within the variable remuneration

12, EU-14a, EU-14b, EU-14y and 16

Of which: deferred

The amounts of variable remuneration by different types of component that are deferred, determined in accordance with Article 94 CRD.

EU-13a

Of which: shares or equivalent ownership interests

The sum of the amounts of shares or equivalent ownership interests, subject to the legal structure of the institution concerned referred to in point (l)(i) of Article 94(1) CRD, within the variable remuneration

EU-13b

Of which: share-linked instruments or equivalent non-cash instruments

The sum of the amounts of share-linked instruments or equivalent non-cash instruments referred to in point (l)(i) of Article 94(1) CRD, within the variable remuneration

EU-14x

Of which: other instruments

The amount of other instruments referred to in point (l)(ii) of Article 94(1) CRD, within the variable remuneration

15

Of which: other forms

The amounts of variable remuneration awarded for the financial year that are other than those disclosed in other rows under the variable remuneration heading

17

Total remuneration

Sum of amounts in rows 2 and 10 of this template.

Column letter

Explanation

a

MB Supervisory function

The Management Body in its Supervisory function, as the management body acting in its role of overseeing and monitoring management decision-making, as defined in point (8) of Article 3(1) CRD

Institutions shall disclose information based on headcount.

In accordance with Article 13 CRR, EU parent institutions shall disclose this information on the basis of their consolidated situation and large subsidiaries of EU parents institutions shall disclose this information on an individual basis or, where applicable in accordance with this Regulation and with CRD, on a sub-consolidated basis. The disclosure entity will reflect in this column information on their management body. If following Articles 6 and 13 CRR, the disclosure is at consolidated or sub-consolidated level, information on the identified staff of the management bodies of the subsidiaries shall be disclosed under the relevant business area

b

MB Management function

The members of the Management Body, who are responsible for its Management functions

Institutions shall disclose information based on headcount.

Institutions shall disclose information based on headcount. In accordance with Article 13 CRR. EU parent institutions shall disclose this information on the basis of their consolidated situation and large subsidiaries of EU parents institutions shall disclose this information on an individual basis or, where applicable in accordance with this Regulation and with CRD, on a sub-consolidated basis .The disclosure entity will reflect in this column information on their management body. If following Articles 6 and 13 CRR, the disclosure is at consolidated or sub-consolidated level, information on the identified staff of the management bodies of the subsidiaries shall be disclosed under the relevant business area

c

Other senior management

Senior management as defined in point (9) of Article 3(1) CRD

Institutions shall disclose the number of senior managers that are not disclosed under Management Body in its management function and as Other identified staff. Institutions shall disclose information based on FTE.

d

Other identified staff

Other staff than Management Body in its Supervisory function or in its Management function, and other than senior management, whose professional activities have a material impact on the institution’s risk profile in accordance with the criteria set out in the Commission Delegated Regulation on identified staff implementing Article 94(2) CRD and where appropriate in addition based on institutions’ criteria

Institutions may include in this template the breakdown by business areas proposed in template EU REM5. Institutions shall disclose information based on FTE.

Legal references and instructions

Row number

Explanation

1, 4 and 6

Number of identified staff

The number of identified staff whose professional activities have a material impact on the institutions’ risk profile in accordance with Article 92 CRD and the Commission Delegated Regulation on identified staff implementing Article 94(2) CRD, for each specific remuneration components

For columns a and b (MB) of this template the value shall be based on headcount. For columns c and d of this template the value shall be calculated using the FTE (full time equivalent) method.

Row 4 of this template refers to severance payments awarded in previous periods and paid out during the financial year (present year) while row 6 of this template refers to awarded during the financial year (present year).

2

Guaranteed variable remuneration awards – Total amount

The amount of guaranteed variable remuneration awards, as referred to in point (e) of Article 94(1) CRD.

3

Of which, guaranteed variable remuneration awards paid during the financial year, that are not taken into account in the bonus cap

The amounts of guaranteed variable remuneration awards as referred to in point (e) of Article 94(1) CRD paid during the financial year (present year), which are not taken into account in the bonus cap

With regard to the disclosed information referred to in points (g) and (h)(v)-(vi) of Article 450(1) CRR, institutions shall clearly state whether the aggregate quantitative information on remuneration broken down by business area reflects the bonus cap when new sign-on and severance payments are involved.

5

Severance payments awarded in previous periods, that have been paid out during the financial year – Total amount

The amount of severance payments as referred to in point (h) of Article 94(1) CRD that have been awarded in previous periods and have been paid out during the financial year (present year)

7

Severance payments awarded during the financial year – Total amount

The amount of severance payments as referred to in point (h) of Article 94(1) CRD, awarded during the financial year (present year)

8

Of which, severance payments awarded during the financial year – Paid during the financial year

The amount of severance payments as referred to in point (h) of Article 94(1) CRD, awarded during the financial year that has been paid during the financial year

9

Of which, severance payments awarded during the financial year – Deferred

The amounts of severance payments as referred to in point (h) of Article 94(1) CRD, awarded during the financial year, which are deferred, determined in accordance with Article 94 CRD

10

Of which, severance payments paid during the financial year, that are not taken into account in the bonus cap

The amounts of severance payments as referred to in point (h) of Article 94(1) CRD, paid during the financial year, which are not taken into account in the bonus cap

With regard to the disclosed information referred to in points (g) and (h)(v)-(vi) of Article 450(1) CRR, institutions shall clearly state whether the aggregate quantitative information on remuneration broken down by business area reflects the bonus cap when new sign-on and severance payments are involved.

11

Of which, severance payments awarded during the financial year – Highest payment that has been awarded to a single person

The amount of the highest severance payment, as referred to in point (h) of Article 94(1) CRD, that has been awarded to a single person during the financial year.

Column letter

Explanation

a

MB Supervisory function

The Management Body in its Supervisory function, as the management body acting in its role of overseeing and monitoring management decision-making, as defined in point (8) of Article 3(1) CRD (Headcount)

b

MB Management function

The members of the Management Body, who are responsible for its Management functions (Headcount)

c

Other senior management

Senior management as defined in point (9) of Article 3(1) CRD

Institutions shall disclose the number of senior managers that are not disclosed under Management Body in its management function and as Other identified staff (FTE).

d

Other identified staff

Other staff than Management Body in its Supervisory function or in its Management function, and other than senior management, whose professional activities have a material impact on the institution’s risk profile in accordance with the criteria set out in the Commission Delegated Regulation on identified staff implementing Article 94(2) CRD and where appropriate in addition based on institutions’ criteria

Institutions may include in this template the breakdown by business areas proposed in template EU REM5 (FTE).

Legal references and instructions

Row number

Explanation

1

MB Supervisory function

The Management Body in its Supervisory function, as the management body acting in its role of overseeing and monitoring management decision-making, as defined in point (8) of Article 3(1) CRD

Sum of amounts in rows 2, 3, 4, 5, and 6 of this template

2, 8, 14 and 20

Cash-based

The amount of cash-based remuneration within the variable remuneration

3, 9, 15 and 21

Shares or equivalent ownership interests

The sum of the amounts of shares or equivalent ownership interests, subject to the legal structure of the institution concerned referred to in point (l)(i) of Article 94(1) CRD, within the variable remuneration

4, 10, 16 and 22

Share-linked instruments or equivalent non-cash instruments

The sum of the amounts of share-linked instruments or equivalent non-cash instruments referred to in point (l)(i) of Article 94(1) CRD, within the variable remuneration

5, 11, 17 and 23

Other instruments

The amount of other instruments referred to in point (l)(ii) of Article 94(1) CRD, within the variable remuneration

6, 12, 18 and 24

Other forms

The amounts of variable remuneration other than disclosed in rows ‘Cash-based’, ‘Shares or equivalent ownership interests, subject to the legal structure of the institution concerned or share-linked instruments or equivalent non-cash instruments’ and ‘Other instruments’

This could include proportionate regular pension contributions, or benefits (where such benefits are without consideration of any performance criteria), referred to in recital (64) CRD, or other forms of remuneration like car allowances.

7

MB Management function

The members of the Management Body, who are responsible for its Management functions; sum of amounts in rows 8, 9, 10, 11 and 12 of this template.

13

Other senior management

Senior management as defined in point (9) of Article 3(1) CRD; sum of amounts in rows 14, 15, 16, 17 and 18 of this template

Institutions shall disclose the number of senior managers that are not disclosed under Management Body in its management function and as Other identified staff.

19

Other identified staff

Other staff than Management Body in its Supervisory function or in its Management function, and other than senior management, whose professional activities have a material impact on the institution’s risk profile in accordance with the criteria set out in the Commission Delegated Regulation on identified staff implementing Article 94(2) CRD and where appropriate in addition based on institutions’ criteria; sum of amounts in rows 20, 21, 22, 23 and 24 of this template

25

Total amount

Sum of amounts in rows 1, 7, 13 and 19 of this template

Column letter

Explanation

a

Total amount of deferred remuneration awarded for previous performance periods

The amount of deferred remuneration, as determined in accordance with Article 94 CRD, that has been awarded for previous performance periods (sum of amounts in columns b and c of this template)

b

Of which due to vest in the financial year

The amount of deferred remuneration awarded for previous performance periods, as determined in accordance with Article 94 CRD, that is due to vest in the financial year

c

Of which vesting in subsequent financial years

The amount of deferred remuneration awarded for previous performance periods, as determined in accordance with Article 94 CRD, that will be vested in the subsequent financial years

d

Amount of performance adjustment made in the financial year to deferred remuneration that was due to vest in the financial year

The amount of performance adjustment to deferred remuneration, as determined in accordance with Article 94 CRD, that was due to vest in the financial years

e

Amount of performance adjustment made in the financial year to deferred remuneration that was due to vest in future financial years

The amount of performance adjustment to deferred remuneration, as determined in accordance with Article 94 CRD, that was due to vest in future performance years

f

Total amount of adjustment during the financial year due to ex post implicit adjustments during the financial year (i.e. changes of value of deferred remuneration due to the changes of prices of instruments)

When relevant the amount of change of value during the financial year due to ex post implicit adjustments, like changes of value of deferred remuneration due to the changes of prices of instruments, estimated on a best effort basis.

EU - g

Total amount of deferred remuneration awarded before the financial year actually paid out in the financial year

The amount of deferred remuneration, as determined in accordance with Article 94 CRD, that has been paid out in the financial year

As soon as the deferred remuneration is vested it shall be considered as paid out.

EU - h

Total of amount of deferred remuneration awarded for previous performance period that has vested but is subject to retention periods

The amount of deferred remuneration, awarded for previous performance periods, that has been vested but is subject to retention periods, as determined in accordance with Article 94 CRD

Legal references and instructions

Row number

Explanation

1 to 8

Remuneration between 1 and 5 million EUR per financial year, broken down by 500.000 EUR bands

9 to x

Remuneration more than 5 million EUR per financial year, broken down by 1 million EUR bands

Column letter

Explanation

a

Number of identified staff that have been remunerated EUR 1 million or more per financial year

Institutions shall disclose information based on headcount.

Legal references and instructions

Row number

Explanation

1

Total number of identified staff

Staff members, whose professional activities have a material impact on institutions’ risk profile (identified staff) of an institution and its subsidiaries, including subsidiaries not subject to the CRD and all members of their respective management bodies

The value shall be disclosed based on FTE.

2

Of which: members of the MB

The number of members in the respective Management body in its Supervisory function and in its Management function, and in the whole Management body

3

Of which: other senior management

Other staff than the members of the Management Body, who are senior management as defined in point (9) of Article 3(1) CRD

4

Of which: other identified staff

Other staff than members of the Management Body, and other than senior management, whose professional activities have a material impact on the institution’s risk profile in accordance with the criteria set out in the Commission Delegated Regulation on identified staff implementing Article 94(2) CRD and where appropriate in addition based on institutions’ criteria

5

Total remuneration of identified staff

The total amount of remuneration shall mean all forms of fixed and variable remuneration and shall include payments and benefits, monetary or non-monetary, awarded directly to staff by or on behalf of institutions in exchange for professional services rendered by staff, carried interest payments within the meaning of point (d) of Article 4(1) of Directive 2011/61/EU (1), and other payments made via methods and vehicles which, if they were not considered as remuneration, would lead to a circumvention of the remuneration requirements of CRD.

6

Of which: variable remuneration

The sum of all remuneration components which are not fixed remuneration that are referred to in row 7 of this template.

7

Of which: fixed remuneration

Institutions shall consider remuneration fixed where the conditions for its award and its amount:

a.  are based on a predetermined criteria;

b.  are non-discretionary reflecting the level of professional experience and seniority of staff;

c.  are transparent with respect to the individual amount awarded to the individual staff member;

d.  are permanent, i.e. maintained over a period tied to the specific role and organisational responsibilities;

e.  are non-revocable; the permanent amount is only changed via collective bargaining or following renegotiation in line with national criteria on wage setting;

f.  cannot be reduced, suspended or cancelled by the institution;

g.  do not provide incentives for risk assumption; and

h.  do not depend on performance.

Column letter

Explanation

a, b and c

Management body (MB)

The Management body of the institution, with the breakdown of Supervisory function and Management function

Institutions shall disclose information based on headcount.

d to h

Business areas

The major business areas of the institution, as Investment banking, Retail banking, Asset management, Corporate functions, Independent internal control functions

Information shall be disclosed based on FTE.

i

All other

All other business areas that were not covered in the previous columns separately

Information shall be disclosed based on FTE.