Our remuneration policy governs the management of remuneration to employees. The remuneration policy contributes to sound and efficient risk management and counteracts employees taking excessive risks. This is good both for Nordiska’s customers and for us as a company.
The management of variable remuneration to employees
Nordiska's remuneration policy aims to ensure the above and that Nordiska has internal rules for its remuneration system that meet the requirements set out in Finansinspektionen's regulations (FFFS 2011 : 1) on remuneration systems in credit institutions, etc., as well as other applicable regulations in the field, in particular 2013/36 / EU on authorisation to conduct activities in credit institutions and investment firms (the "Capital Adequacy Directive"), and the EBA's guidelines on sound remuneration policy pursuant to Articles 74 (3) and 75.2 of Directive 2013/36 / EU and information pursuant to Article 450 of Regulation (EU) No 575/2013.
To be an attractive employer and retain competence
Nordiska shall, as a credit institution, ensure a sound risk culture and operations in Nordiska. Nordiska's promotion of sound and efficient risk management and counteracting excessive risk-taking are of great importance for Nordiska's public confidence and long-term profitability and stability.
Nordiska's long-term goal is that the business is conducted in such a way that Nordiska's ability to fulfil its obligations does not jeopardise its position. Nordiska's remuneration system shall contribute to this by being sound, reasonable and aimed at motivating employees. At the same time, it must also be long-term value-creating and entail a well-balanced level of risk for Nordiska.
In order to be able to attract, motivate and retain competent staff, it is essential that Nordiska can offer remuneration to all its employees that is competitive in the market and in the segment in which Nordiska operates. Employees shall be offered remuneration and other benefits that in relation to Nordiska's conditions are reasonable, market-based and competitive.
Remuneration practices shall be gender-neutral.
Nordiska's Board of Directors adopts a remuneration policy in which the bases and principles for how remuneration within Nordiska are to be determined, how the remuneration policy is to be applied and followed up and how employees whose duties have a significant impact on Nordiska's risk profile are to be identified. The remuneration policy covers all employees at Nordiska, the Board members and contractors.
The Board has decided that at present there shall be no variable remuneration, either as part of salary or as a pension benefit. The employees must thus only be offered fixed compensation. No employee receives variable remuneration as defined in this policy, see also Nordiska's risk analysis.
The Board of Directors decides on remuneration to the Executive Management, compensation to employees who have the overall responsibility for any of the Company's Control Functions, and measures to monitor the application of this policy. The Board's decision shall also, where applicable, follow what the Annual General Meeting has decided in terms of remuneration in Nordiska.
Information on remuneration is published in the Company's annual report.
Nordiska conducts and adopts an annual risk analysis with the aim of identifying employees whose duties have a significant impact on Nordiska's risk profile. The Board is responsible for approving the process for the risk analysis by establishing the remuneration policy.
The risk analysis is based on the qualitative and quantitative criteria contained in delegated regulation (EU) 604/2014 of 4 March 2014 and additional criteria that reflect Nordiska's assessment of tasks that have a significant impact on the risk profile.
The following categories of employees as employees with a significant impact on the company's risk profile.
|Number of persons|
|Employees in the executive management||5|
|Employees responsible for control functions||3|
Persons with management responsibility for the Company's control functions or significant business units
|Other risk takers||0|
Employees whose remuneration amounts to, or exceeds, the total remuneration to someone in the executive management, have remuneration in excess of EUR 500,000 or has the highest remuneration in the company *.
* According to EU No 604/2014: within the group 0.3% of employees with the highest remuneration (rounded to full person). Taking into account the Company's size, this currently corresponds to one person.
With regard to e.g. the remuneration system that the Company currently applies, in particular that no variable remuneration is paid, the identification of the above categories does not entail any special consequences in terms of remuneration.
All Nordiska employees have fixed remuneration. The fixed remuneration is market-adapted and is based on the employee's position, responsibility, competence, performance and current market conditions and consists of a monthly cash salary. The total fixed remuneration must follow Nordiska's values and support Nordiska's goals and visions. Nordiska's employed advisers receive to some extent commission-based salary which, according to Nordiska's risk analysis, is not considered to constitute variable remuneration. Remuneration is paid in the form of cash or in the form of customary pension provisions.
Special appointed member of the Board
The Board shall appoint a member from within with responsibility for certain issues concerning remuneration. The member in question must not be part of the company's executive management, and must have sufficient knowledge and experience in matters of risk management and remuneration.
On an annual basis, the assigned member must perform an independent assessment of the company's remuneration policy and remuneration system. The assigned member shall also prepare Board decisions on remuneration and measures. The preparation shall take into account the long-term interests of shareholders, investors and other stakeholders. Internal auditors shall participate in the assessment and evaluation process that the CEO and the special Board member shall carry out.
The Internal Audit function shall at least annually review whether Nordiska's remuneration system complies with the remuneration policy. The function for Internal Audit shall regularly report the results of its review to the Board of Nordiska. At the latest in connection with the adoption of the annual report, the function shall report the results of the review to the Board.