Regulatory Alerts2018-04-26
Guidelines on the Application of the Proportionality Principle Regarding the Remuneration Policy of Investment Fund Management Companies and the Exemption for Small Remuneration
The Croatian Financial Services Agency (Hanfa) issued these Guidelines to clarify how investment fund management companies should apply the proportionality principle and the small remuneration exemption under their remuneration policies. The document establishes a common framework requiring management companies to conduct a documented proportionality test based on size, organizational structure, and activity complexity to determine whether they are significant or non-significant. Significant companies must fully apply remuneration policy requirements except for the small remuneration pay-out exemption, while non-significant companies may be exempt from establishing a remuneration committee and must apply remaining requirements proportionally, with assessments reviewed at least biennially.