Remuneration policy

StartGreen Capital has a remuneration policy based on the Financial Institutions Remuneration Policy Act as contained in Book 1 Wft Chapter 1.7. This applies to all employees of StartGreen Capital. The remuneration policy aims to ensure that remuneration of employees does not create undesirable risks or behaviour with regard to clients or solidity/continuity of StartGreen Capital.

The remuneration policy has been adopted by the Management Board and reviewed by the Compliance Officer. At least annually, the remuneration policy is reviewed to see whether it meets the requirements of the Management Board, applicable laws and regulations and the interests of our clients. This review considers whether all forms of remuneration may encourage undesirable behaviour and how the remuneration policy provides for appropriate control measures. If necessary, the review may be conducted more frequently.

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

For variable remuneration, performance indicators are established based on an assessment of whether the remuneration will generate risk-seeking behaviour and the measures to prevent this. A variable remuneration is awarded only in the event of a positive assessment based on the performance indicators, among others, and if StartGreen Capital's financial situation allows. Over 2023, 20 employees received variable remuneration.

StartGreen has a statutory objective to "through its business operations and activities, have a significantly positive impact on society and the environment at large". Employee remuneration is therefore always linked to targets that ideally make a positive contribution to, but in no case have a negative impact on, any of the Sustainable Development Goals. Investments and financing may only qualify for the quantitative targets if the ESG risks have been sufficiently assessed and ratified beforehand by the mandated committee.

Disbursed variable remuneration of management board and employees can be reclaimed up to the full amount up to three years after disbursement if StartGreen Capital is of the opinion that, in retrospect, the variable remuneration awarded proved to be unjustified based on incorrect or missing information at the time. This is done by board resolution.

The law requires StartGreen Capital to disclose whether any single person or shareholder receives remuneration exceeding EUR 1 million on an annual basis. This is obviously not the case, StartGreen complies with the Top Income Standardisation Act.