Controlled remuneration policy Deck
Managed remuneration policy is important in striving for a corporate culture that puts the customer's interests first. As regulator, the AFM ensures that the remuneration policy of financial enterprises does not provide perverse incentives.
In order to implement a controlled remuneration policy, we have drawn up a procedure that ensures this. In addition, we monitor annually whether reality is still in line with the desired controlled remuneration policy. This document sets out this remuneration policy.
Table of contents
Risk analysis
Written record of the policy
Measures and procedures to prevent risks
Disclosure of policy
1. Risk analysis
What types of rewards are possible?
In our company, we only have fixed remuneration for employees.
Based on what performance criteria is the transaction rate or percentage increased?
Annual reviews are conducted and may lead to the adjustment of the fixed remuneration.
How is the variable remuneration structured?
No variable rewards are paid within our company.
Are opinions reviewed for appropriateness (randomly)?
All opinions are stored; randomly reviewed and discussed in a meeting between employee and the policymaker.
Are there other management measures that can prevent careless client handling?
For all financially complex advice, there is an inventory form that is actively applied. In addition, all staff have signed our code of integrity and taken the corresponding oath. The application of this code of conduct is also complied with.
Are there any types of positions within the company that carry more risks?
Deck is a small company. So there are functions that combine multiple responsibilities.
2. Written record of policy
Every financial services firm must have a controlled remuneration policy. The policy should be set out in writing and then kept up to date. This policy should prevent the way our employees are rewarded from leading to careless customer treatment. The remuneration policy and its rules apply to all employees, including directors and temporary workers. For a remuneration policy to be controlled, the policy must include sufficient control measures against the incentives.
Risk of careless customer handling must be controlled. The higher the risk, the more intensive the measures must be to counteract actual careless client handling. If it does threaten to take place, timely action should be taken.
The purpose of the remuneration policy
The purpose of our remuneration policy is to ensure that there are no perverse financial incentives in the remuneration of our employees that could harm the interests of our clients. With this remuneration policy, we encourage that all work takes place in the interest of the relationship and we consider it undesirable that advice would be given only to increase turnover or income.
Principles of remuneration policy
The following principles have been used in drafting the remuneration policy:
Market-based remuneration, for the purpose of attracting and retaining qualified employees
Socially responsible and/or justifiable remuneration
Customer interest is paramount
Long-term objectives
Transparency and simplicity
Comply with laws and regulations
Advisor provides appropriate advice at all times
What does the remuneration consist of?
The remuneration consists of a fixed salary.
The appropriateness of the policy within the company's business
The remuneration policy is consistent with the conduct requirements set out by the company.
Who does the policy apply to?
The Controlled Remuneration Policy applies to all employees.
Who is responsible for drafting, applying and evaluating the remuneration policy?
The management is responsible for ensuring that the policy is dynamic and is periodically reviewed and adjusted as necessary.
3. Risk prevention measures and procedures
Procedures we follow and measures we may take include:
Four-eyes principle
Applying and monitoring the use of checklists
Individual interviews with employees
Deduction of compensation
Suspension or termination of cooperation
4. Disclosure of policy
On our website (deck.nl), our controlled remuneration policy can be viewed. The service guide can also be found on our website.
Deck remuneration policy
July 2022
