The purpose of the remuneration policy is to prevent undesirable incentives, conflicts of interest and careless treatment of clients.
The following principles apply to the way the policy is set up:
the client's interest and the quality of our services come first;
remuneration does not encourage advising on or selling a particular product;
remuneration does not encourage unnecessary product switching, higher premiums or more turnover;
remuneration matches the role, responsibility, experience and professional competence;
the policy complies with the Financial Supervision Act (Wet op het financieel toezicht, Wft) and the rules on controlled remuneration policy.
2 Who does the policy apply to?
This policy applies to all natural persons who work for or under the responsibility of Finass Advies B.V., whatever their role or type of contract. This includes, in so far as applicable, employees, directors on the payroll, temporary staff and freelancers who carry out work for the account and risk of Finass Advies B.V.
3 Fixed remuneration
Staff of Finass Advies B.V. receive only fixed remuneration, in the form of regular pay and customary employment conditions.
The level of the fixed salary is determined on the basis of, among other things:
the content and weight of the role;
responsibilities and powers;
relevant education, experience and professional competence;
the quality and care with which the role is performed;
market developments and internal pay relationships.
Any salary adjustment does not depend on the volume, turnover or type of financial products a member of staff advises on, brokes or sells.
4 No variable or turnover-related remuneration
Finass Advies B.V. awards no individual or collective variable remuneration linked to production, turnover, commission, numbers of products sold, premium written, profit or commercial targets.
Staff receive no bonus, share of commission, sales fee, competition prize or other financial reward for advising on or arranging a specific financial product.
The number of persons receiving variable remuneration is therefore nil, and the amount paid out annually in variable remuneration is EUR 0.
5 Non-financial assessment
Non-financial aspects may be taken into account in the supervision and assessment of staff, such as:
careful and understandable client communication;
the quality and completeness of files;
compliance with laws, regulations and internal procedures;
professional competence and continuing professional education;
client satisfaction and correct handling of complaints;
cooperation, integrity and risk awareness.
These aspects are not used to award a turnover-related or product-related bonus.
6 Remuneration of one million euros or more
There are no persons working within Finass Advies B.V. who receive total annual remuneration of EUR 1 million or more.
7 Adjustment and clawback
Because Finass Advies B.V. awards no variable remuneration, procedures for adjusting or clawing back variable remuneration do not apply.
If a variable remuneration component is considered in the future, the policy will be amended in advance and tested against the statutory conditions. This will include appropriate non-financial criteria, risk management, adjustment and clawback arrangements and the applicable bonus cap.
8 Control and evaluation
Finass Advies B.V. assesses periodically whether the remuneration policy and actual remuneration practice still match the size of the firm, its activities, its risks and the applicable laws and regulations.
Signals from complaints, file reviews, compliance, client satisfaction and staff appraisals may be a reason to adjust the policy or the internal control measures.
9 Relationship to our own remuneration from providers
This policy concerns the remuneration of our staff. How our firm itself is remunerated — through commission included in the premium or through a direct fee — is set out in the service guide.
10 Publication and changes
This summary is published on the website to give clients insight into the way Finass Advies B.V. prevents undesirable remuneration incentives.
We may amend this policy when the organisation, the remuneration structure or the laws and regulations change. The date at the top of this page shows when the text was last updated.
