CBL Asset Management IPAS and Citadele banka are part of the Citadele Group, where Citadele banka AS is the parent company of the Group. CBL Asset Management follows the remuneration policy approved by the Group. Objective of the Policy is to attract, motivate, train, and retain professional and talented employees, to assist the Bank/Group in achieving its short-term and long-term goals.
The Citadele Group is committed to fair and reasonable remuneration practices and policies to promote the long-term sustainability and development of the business and to achieve the best interests of both Citadele Group and its employees. The remuneration policy includes, among other things, requirements to comply with the Code of Ethics of the Citadele Group, as well as norms to align employee behaviour with the interests of a wider range of the Citadele Group stakeholders.
Taking into account the number of members of the CBL Asset Management Council and the scope, type, complexity and specificity of its activities, the Council does not establish separate committees. The duties of the Remuneration Committee are performed by the CBL Asset Management Council in its full composition. External experts are not used in determining the remuneration policy. The composition of the CBL Asset Management Council is disclosed here.The growth of assets under management is not the only or the main component of the Remuneration Policy, therefore the risk that individual motivations in making investment decisions may not be aligned with sustainability risk considerations is limited.
Sustainability is an integral part of Citadele's remuneration policy, reflecting our commitment to sound risk management and ethical business practices.
The Group has prepared information on how remuneration policy is consistent with the integration of sustainability risks, which discloses information on:
- Integration of sustainability risks and information on how sustainability risks are considered in the remuneration policy.
- Linking executive and employee remuneration to the achievement of sustainability objectives and long-term value creation.
- Specific sustainability performance indicators on sustainability factors.
- Sustainability outcomes to be achieved.
The priority sustainability objectives are linked to our business and sustainability strategy for the next three years and cover the areas where we have the greatest impact. Information on the Group’s and CBL Asset Management Sustainability Strategy is available here.
Remuneration consists of a fixed part of remuneration and a variable part of remuneration, if applicable. The fixed part of remuneration is determined as a time wage in accordance with the actual working hours worked, regardless of the amount of work performed. The variable part of remuneration depends on the performance results and the achievement of the set goals. In Citadele Group, the variable part can only be formed by costs in monetary form (bonuses for the achievement of quantitative/qualitative indicators and goals, sales commissions, etc.).
Based on the employee's performance and the degree of achievement of the set goals, qualitative and quantitative indicators have been determined: time spent on customer service, document preparation; support for customers with the green transition; indicators related to compliance with regulatory requirements, i.e. indicators related to compliance with regulatory enactments and restrictions that are binding on the employee and that may affect the risk profile and financial results of CBL Asset Management, including sustainability risk.
The Board of Citadele Bank is responsible for determining the job groups and the fixed remuneration limits for each group, taking into account the results of remuneration studies of financial institutions conducted by selected competent organizations. In order to objectively assess the level of fixed remuneration of employees in the labor market, CBL Asset Management regularly participates in both industry and cross-industry remuneration studies.
Citadele Group has determined that positions that affect the risk profile are those that:
- Does not encourage risk-taking above the level set out in the Citadele Group Risk Management Policy and risk appetite.
- Does not limit the ability to strengthen equity, in accordance with the rules for establishing a bonus fund set out in the Remuneration Policy.
- Complies with the values of Citadele Group, such as ethical standards, long-term interests, operational objectives set out in the development strategy, as well as complies with and promotes prudent and effective risk management and prevention of conflicts of interest.
- Does not contradict the principles of protecting the interests of clients or investors and the interests of other stakeholders.
- Takes into account that determining the variable part of the remuneration in a guaranteed amount does not comply with prudent risk management or determining the variable part of the remuneration based on performance in accordance with the requirements of the policy and may not be envisaged in future remuneration plans.
The performance targets set for employees performing internal control functions (risk control, compliance and internal audit functions) are designed to ensure that they are remunerated independently of the performance of the business areas they control.
To further limit excessive risk-taking and reduce the focus on short-term objectives, for job groups that affect the risk profile of the business and portfolios, part of the variable remuneration is deferred for a period of one to three years. Citadele Group follows developments closely and regularly introduces best practices and innovations in sustainable finance and environmental, social and governance (ESG) aspects into the Remuneration Policy.
For more details on the Remuneration Policy, including its objectives, elements of the remuneration structure, principles for determining fixed and variable remuneration, sustainability risk management and the long-term incentive plan, see the Group's remuneration reports under Remuneration Report.
Remuneration Policy