Remuneration Policy StartGreen Capital

StartGreen Capital applies a remuneration policy in accordance with the Dutch Financial Undertakings Remuneration Policy Act (Book 1 Wft, Chapter 1.7) and the Decree on Sound Remuneration Policy Wft. The policy aims to ensure that remuneration does not incentivise the taking of excessive risks, including sustainability risks, and that clients are treated with care.

Governance and assessment

The remuneration policy has been established by the Management Board and reviewed by the Compliance Officer. The policy is reviewed at least annually to ensure it complies with laws and regulations, client interests, and StartGreen Capital's long-term strategy.

Reward structure

All employees receive a fixed monthly salary that is not dependent on objectives. StartGreen Capital may grant discretionary variable remuneration, provided that the financial position allows for it.

The ratio between fixed and variable remuneration is appropriate and amounts to a maximum of 20% of the fixed income. No guaranteed variable remuneration is awarded, except for a sign-on bonus in accordance with Article 1:122 Wft.

Due to its size and shareholder structure, variable remuneration is paid out entirely in cash, in accordance with the proportionality principle.

Criteria for variable remuneration

Variable remuneration is awarded solely based on pre-determined (financial and non-financial) indicators, with at least 50% of the assessment based on non-financial criteria, including ESG factors.

Integration of sustainability risks (SFDR)

In line with Article 5 of the SFDR, the remuneration policy is structured such that it does not contain incentives that could lead to the taking of excessive sustainability risks. Investments and financing are only eligible for quantitative objectives if ESG risks have been assessed and approved in advance by the investment committee. No variable remuneration is awarded based on performance achieved through irresponsible sustainability risks.

Clawback and penalty

The payment of variable remuneration may be reduced in full or in part in the event of breaches of norms, inadequate risk management, or material deterioration of the financial position. Variable remuneration may be clawed back proportionally up to three years after payment in cases of incorrect information, breach of laws or regulations, serious deficiencies in risk management, or irresponsible risk-taking, including sustainability risks.

Transparency

StartGreen Capital complies with the Top Income Standardisation Act.