StartGreen Capital has a remuneration policy based on the Remuneration Policies of Financial Undertakings Act as included in Book 1 of the Financial Supervision Act Chapter 1.7. This applies to all of StartGreen Capital’s employees. The remuneration policy is aimed at ensuring that employee remuneration does not pose undesirable risks or promote certain behaviour towards clients or affect the solidity/continuity of StartGreen Capital.

The remuneration policy has been established by the management board and assessed by the compliance officer. The remuneration policy is reviewed at least once a year to see whether the policy meets the requirements set by the management board, the applicable laws and regulations and the interests of our clients. What we look at is whether any form of remuneration could encourage undesirable behaviour and how the remuneration policy provides appropriate control measures. If necessary, the assessment can be performed more often.

StartGreen Capital pays a fixed monthly fee to all its employees which does not depend on targets being met. StartGreen Capital may pay discretionary variable remuneration which is linked not only to the achievement of criteria relating to employee performance but also to the financial soundness of StartGreen Capital. The ratio between the fixed and variable remuneration is appropriate and the latter may never exceed 20% of the fixed income. StartGreen Capital does not work with guaranteed variable remuneration.

For variable remuneration, performance indicators have been determined based on an assessment of whether the remuneration will result in risk-seeking behaviour and the measures to prevent this. Variable remuneration is only awarded in the event of a positive assessment based on, among other things, the performance indicators and if the financial situation allows StartGreen Capital to do so. Over the past year, 21 employees received variable remuneration.

Variable remuneration paid out to the management board and identified staff can be reclaimed, up to a maximum of the full amount, up to three years after payment if StartGreen Capital is of the opinion that the variable remuneration that was awarded afterwards turns out to be incorrect on the basis of incorrect or missing information at the time. This is carried out by means of a management decision.

Variable remuneration paid out to the management board and identified staff can be reclaimed, up to a maximum of the full amount, up to three years after payment if StartGreen Capital is of the opinion that the variable remuneration that was awarded afterwards turns out to be incorrect on the basis of incorrect or missing information at the time. This is carried out by means of a management decision.

The law requires StartGreen Capital to state whether a single person or shareholder receives remuneration that exceeds 1 million euros on an annual basis. Obviously, this is not the case, StartGreen adheres to the Top Incomes (Standards) Act.