Remuneration policy

StartGreen Capital has a remuneration policy based on Financial Enterprises Remuneration Policy Act as included in Book 1 Wft Chapter 1.7. This applies to all employees of StartGreen Capital. The remuneration policy is aimed at ensuring that employee remuneration does not pose undesirable risks or behavior towards clients or the solidity / continuity of StartGreen Capital.

The remuneration policy has been established by the management and assessed by the compliance officer. The remuneration policy is reviewed at least annually to see whether the policy meets the requirements of the board of management, applicable laws and regulations and the interests of our clients. It is examined whether all forms of remuneration can stimulate undesirable behavior and how the remuneration policy provides for appropriate control measures. If necessary, the assessment can be performed more often.

StartGreen Capital pays out a fixed monthly fee to all employees that does not depend on objectives. StartGreen Capital can pay discretionary variable rewards, these are rewards that are linked to the achievement of criteria in relation to the performance of the employee, but also the financial soundness of StartGreen Capital. The ratio between fixed and variable remuneration is appropriate and can never exceed 20% of the fixed income. StartGreen Capital does not work with guaranteed variable remuneration.

For variable remuneration, performance indicators are determined on the basis of an assessment of whether the remuneration will result in risk-seeking behavior 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. Over the past year, 21 employees received variable remuneration.

StartGreen has the statutory objective to 'through its business operations and activities, have a significant positive influence on society and the environment in general'. The remuneration of employees must therefore always be linked to objectives that ideally make a positive contribution to, but in no case have a negative impact on, one of the sustainable development goals. Investments and financing may only be eligible for the quantitative targets if the ESG risks have been sufficiently assessed and endorsed in advance by the committee mandated for this purpose.

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

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