Report on Nordic Issuing’s remenuration policy

Report on Nordic Issuing’s remuneration policy

Nordic Issuing’s remuneration rules are designed in accordance with the requirements set out in external rules and comply with the remuneration rules established for Spotlight Group AB and its subsidiaries. The board of Nordic Issuing establishes and updates an annual Remuneration Policy (Ersättningspolicy) based on the Swedish Financial Supervisory Authority’s regulations (FFFS 2017: 2) after preparation by the Remuneration Committee. The law firm MCL monitors rule changes and proposes ongoing updates to Nordic Issuing’s compensation rules. A review of the regulations takes place at least once a year and in connection with changes in external rules or internal conditions. When updating the Remuneration Policy, representatives from the Risk management function and the Compliance function are involved.

The board has, in a balanced assessment, decided that all employees shall receive a fixed salary with the possibility of variable remuneration. Variable remuneration is only paid if the remuneration committee and Group management have assessed the criteria set out in the remuneration policy. There is a suitable balance between fixed and variable parts where the variable compensation may in no case be greater than the fixed compensation. By maintaining this balance, the compensation structure does not create any incentives that can cause employees to benefit their own or Nordic Issuing’s interests to the potential detriment of the customer’s interests. The internal auditor reviews that the remuneration system complies with the Remuneration Policy annually and reports the results to the Board.