Regulatory Alerts2022-12-21
Guidelines on the Application of the Proportionality Principle Regarding Remuneration Policy of Investment Fund Management Companies and Small Remuneration Exemption
The Croatian Financial Services Agency (Hanfa) issued these Guidelines to standardize how investment fund management companies apply the proportionality principle to their remuneration policies. The document establishes a unified framework requiring management companies to conduct documented proportionality tests based on size, organizational structure, and activity complexity, thereby determining whether they are classified as significant or non-significant. Significant companies must fully apply remuneration requirements except for small remuneration pay-out exemptions, while non-significant companies may be exempt from establishing a remuneration committee and can apply pay-out rules proportionally, with exemptions never occurring automatically.