Besides regulating the design of compensation systems and the clarity of compensation principles, the legislation also sets out requirements for the governance of compensation at banks. In the case of larger institutions, this responsibility is spread across a number of individuals within the organization.
As part of the implementation of the European Capital Requirements Directive (CRD) IV, the German legislator has introduced a number of amendments to the German Banking Act (Kreditwesengesetz) and the Remuneration Ordinance for Institutions (Institutsvergütungsverordnung).
In particular, the legislation now requires institutions to set up a "compensation control committee" at the level of the supervisory body. The task of this committee is to monitor the appropriate design of the compensation systems, and their impact in terms of their alignment with the bank's risk management system. The legislation also requires major institutions to appoint a "compensation officer" to support the compensation control committee in its monitoring duty. The compensation officer must be integrated into the ongoing application of the compensation systems and any conceptual redevelopment or further development of them.
hkp/// group has developed a ten-point plan for implementing the compensation officer function at banks. We use this methodology to help organizations with the appointment of officers (examination of qualifications, position in terms of function and within the organizational hierarchy), their ongoing training (seminars, workshops, etc.) and the exercise of their duties (documentation in organizational guidelines, planning of monitoring activities, compensation control reports).