Page 66 - CCB_Full-Annual-Report-2021

66 67

Contents
Contents

Disclosures: Remuneration
As a regulated BIPRU Bank, Cambridge
& Counties Bank will provide the Strategic Report
appropriate remuneration disclosures for
a proportionality Tier 3 Bank within its
Pillar 3 disclosure, which is published on
the Bank’s website.

Roles & Responsibilities
The Chief People Officer is responsible for
the maintenance of this policy and ensures
that Risk & Compliance are made aware of
any changes to enable the policy review Corporate Governance Statement
schedule to be updated.
In respect of determining if Malus and/or Termination of employment Policy Breaches
Clawback should be invoked in terms of a The Bank’s redundancy policy is to pay Any breaches of this policy will be reported Reward outcomes in 2021
Trigger Event which has been discovered, statutory redundancy pay. Exceptionally, to the Chief Risk Officer who will make The Performance & Remuneration
the Performance & Remuneration if required from a business need, the Bank an assessment as to whether further Committee has reviewed the business
Committee may consider an individual’s will enter into agreed settlement payments notification to the regulator is necessary. performance in 2021 and considered risk
proximity to the applicable Trigger Event which are calculated on current base salary Significant breaches which require a events in conjunction with the Board Risk
and his or her level of responsibility.
and may include awarded but deferred notification to the regulators include (but & Compliance Committee, the affordability
bonus payments. It is the Bank’s policy not are not limited to): of paying variable pay, and the associated
The Board is empowered with absolute to include any element of future earnings risk of low variable pay. After assessment of
discretion to enforce or decline to apply or awards. The LTiP and Senior Leadership ∞ any proposed changes to remuneration performance, the Committee has approved
Malus and Clawback and should, in Plan schemes do include good leaver policies, practices or procedures which distribution of £2.2m variable pay award for
determining whether to enforce or decline status and the reasons for termination could have a significant impact on the 2021 (2020: £1.4m).
it, consider the interests of the Bank and of employment are considered when firm’s risk profile or resources; Independent Auditor’s Report
its shareholders. In making decisions, the determining any award to ensure they are
Board may take into consideration the proportionate and reflect performance. ∞ fraud, errors, and other irregularities
following factors:
which may suggest weaknesses in, or
be motivated by the firm’s remuneration
∞ the likelihood of success of invoking policies, procedures or practices;
Clawback and recovering such variable
remuneration amounts; The Remuneration ∞ any proposed policies, procedures or

∞ the likelihood that such claim may Policy documents practices which could:
prejudice the interests of the Bank; – have a significant adverse impact on
the policies, the firm’s reputation; Financial Statements
∞ the passage of time since the
occurrence of the Trigger Event(s); and practices and – affect the firm’s ability to continue

∞ the existence of any legal proceedings procedures to provide adequate services to
customers;
against an individual related to the
applicable Trigger Event(s). linked to salary, – result in a serious detriment to a

Before invoking Malus or Clawback the compensation customer of the firm;
Board will advise the affected individual in – result in serious financial
writing of its reasons for intending to invoke and reward of consequences to the financial system
it. An individual will be given an opportunity or to other firms.
to make representations to the Board (in employees. It is Notes to the Financial Statements
writing, within a specified period) about Such notifications will be made as soon
any factors or circumstances that may be reviewed and as the Bank becomes aware of or has
relevant to the application of the Board’s information which reasonably suggests
discretion in invoking Malus or Clawback. approved annually. such circumstances have occurred or may
occur in the future.