Information about the Saxo Bank Group Remuneration Policy and SFDR article 5

For the Saxo Bank Group, it is essential that employees working in the business areas to which the Saxo Bank Group's policies on sustainability risks relate comply with the relevant policies on sustainability risks.

Under the Saxo Bank Group Remuneration Policy, it is therefore a requirement that for employees whose work is related to discretionary portfolio management services, pension and financial advisory services (or other positions if deemed relevant to article 5 of Directive 2019/2088 “SFDR”), one or more of the KPIs set out for the individual employee must be linked to compliance with the Saxo Bank Group Sustainability Risk Policy, which the employees must comply with for the proper performance of their work.

In relation to the Saxo Bank Group’s decision on whether or not an employee should be awarded a bonus under the bonus scheme, negative non-financial performance in the form of unethical or non-compliant behavior must override any good financial performance generated by the Saxo Bank Group, the business unit/the company in which the employee is employed and the employee and, to the extent relevant considering the employee’s position and responsibilities, the same must apply with regard to other non-financial performance criteria.