Page 67 - CCB_Annual Report_2022

66 Corporate Governance Statement 67

Guaranteed Variable Remuneration • the fact that any information used to Termination of employment
determine the quantum of a variable
Signing-on or buy-out guaranteed variable remuneration amount based on The Bank’s redundancy policy is to pay
remuneration are given on the basis of: statutory redundancy pay. Exceptionally,
error, or inaccurate or misleading if required from a business need, the Bank
• being exceptional; information; and/or will enter into agreed settlement payments
• occur only in the context of hiring a • action or conduct of an individual which are calculated on current base salary
new employee; which, in the reasonable opinion of the and may include awarded but deferred
• made only where the Bank has a sound Board/Performance & Remuneration bonus payments. It is the Bank’s policy not
and strong capital base; Committee, amounts to serious to include any element of future earnings
• and are limited to the first year of service misconduct or gross negligence; or awards. The Senior Leadership Plan
unless approved by the Committee. scheme includes good leaver status and
• events or behaviours of an individual or
The Bank does not routinely use early the existence of events attributable to the reasons for termination of employment
termination or settlement payments. Where an individual which led to the censure are considered when determining any
they are employed, they are in line with of the Bank, by a regulatory authority award to ensure they are proportionate and
regulation and reflect loss of office and/or or have had a significant detrimental reflect performance.
redundancy payments. They do not exceed impact on the reputation of the Bank.
the Bank’s variable pay cap. Previously Policy Breaches
awarded bonuses will only be paid where an In respect of determining if Malus and/or Any breaches of this policy will be reported
individual is deemed to be a “good leaver” Clawback should be invoked in terms of a to the Chief Risk Officer who will make
and their performance is strong; post-event Trigger Event which has been discovered, an assessment as to whether further
risk assessments will apply. Settlement the Performance & Remuneration notification to the regulator is necessary.
payments or “pay offs” are not made in Committee may consider an individual’s Significant breaches which require a
cases of poor conduct or performance. proximity to the applicable Trigger Event notification to the regulators include (but
and his or her level of responsibility.
Malus and Clawback are not limited to):
The Board is empowered with absolute • any proposed changes to remuneration
Malus means the reduction and /or discretion to enforce or decline to apply policies, practices or procedures which
cancellation of unpaid, unvested, or Malus and Clawback and should, in could have a significant impact on the
unsettled variable amounts of remuneration determining whether to enforce or decline firm’s risk profile or resources; Disclosures: Remuneration
when a Trigger Event is discovered, and it, consider the interests of the Bank and
the Board seeks to fulfil its fiduciary duty its shareholders. In making decisions, the • fraud, errors, and other irregularities As a regulated BIPRU Bank, Cambridge
to shareholders by invoking its discretion Board may take into consideration the which may suggest weaknesses in, or & Counties Bank will provide the
to reduce and/or cancel a variable following factors: be motivated by the firm’s remuneration appropriate remuneration disclosures for a
remuneration amount. policies, procedures or practices; proportionality Tier 3 Bank within its Pillar
• the likelihood of success of invoking 3 disclosure, which is published on the
Clawback means when incentive Clawback and recovering such variable • any proposed policies, procedures or Bank’s website.
remuneration has already vested, been remuneration amounts; practices which could:
settled, paid, or otherwise made available, • the likelihood that such claim may – have a significant adverse impact on Roles & Responsibilities
and a Trigger Event occurs which indicates prejudice the interests of the Bank; the firm’s reputation;
an error in the calculation of an individual’s The Chief People Officer is responsible for
remuneration, and the Board seeks to • the passage of time since the – affect the firm’s ability to continue the maintenance of this policy and ensures
fulfil its fiduciary duty to shareholders by occurrence of the Trigger Event(s); and to provide adequate services to that Risk & Compliance are made aware of
invoking its discretion to recoup all or part • the existence of any legal proceedings customers; any changes to enable the policy review
of a variable remuneration amount. schedule to be updated.
against an individual related to the – result in a serious detriment to a
A Trigger Event includes but is not applicable Trigger Event(s). customer of the firm; Reward outcomes in 2022
limited to:
Before invoking Malus or Clawback the – result in serious financial
• a material misstatement of the financial Board will advise the affected individual consequences to the financial system The Performance & Remuneration
Committee has reviewed the business
results resulting in an adjustment in the in writing of its reasons for intending to or to other firms. performance in 2022 and considered risk
Bank’s audited accounts; invoke it. An individual will be given an Such notifications will be made as soon events in conjunction with the Board Risk
opportunity to make representations
• in the case of awards which are subject to the Board (in writing, within a as the Bank becomes aware of or has & Compliance Committee, the affordability
to the achievement of performance specified period) about any factors or information which reasonably suggests of paying variable pay, and the associated
conditions, the assessment of any circumstances that may be relevant to the such circumstances have occurred or may risk of low variable pay. After assessment of
performance metric or condition application of the Board’s discretion in occur in the future. performance, the Committee has approved
based on error, or inaccurate or invoking Malus or Clawback. distribution of £2.5m variable pay award for
misleading information; 2022 (2021: £2.2m).