Remuneration Policy

1. Introduction

The company has put in place a compensation structure for all its collaborators, including senior executives and those in charge of control functions, which aims to prevent potential conflicts of interest or the taking of undue risks. This document describes the policy and procedures relating to remuneration.

2. Policy

The following principles constitute the company's remuneration policy.

1. Consistent and harmonious as a whole
   The company has a clear salary scale by skill level and department. This grid is consistent and harmonious in the sense that it presents the same logic and aims to avoid too great a disparity.

2. Differentiated according to objectives
   Remuneration can be differentiated by department. For example, the variable remuneration component of the sales department could be more important than that of the IT department.

3. Aligned with market practices
   The company is committed to providing a competitive remuneration package and structuring it in line with the industry.

4. Fair and motivating
   Remuneration between employees must be fair and avoid excessive differences for functions that provide similar value to the company. Remuneration is an important tool in the employee's contribution to the company.

5. Conditional on an annual performance evaluation
   Variable remuneration, as well as any increase in remuneration, are decided on a collegial basis in the light of a formal, annual assessment of the employee's performance.

6. Multiple components
   The company can use a multitude of components to constitute a collaborator's remuneration package: fixed remuneration, variable bonus, stock option plan, company car, luncheon vouchers, group pension and hospitalization insurance, laptop, smartphone, etc.

7. Discourages reckless risk taking
   The remuneration structure discourages undue risk-taking on the part of collaborators. For example, no remuneration is linked to the performance of the investments in the portfolios under management.

8. Prevents conflicts of interest
   The remuneration structure must avoid conflicts of interest. For example, the variable part of a remuneration package cannot be linked to the commercial performance of one product as opposed to another that might be more suited to a client's situation.

9. Remuneration Governance
   The Board of Directors is responsible for the development of guidelines and the validation of the company's remuneration grids. Given its modest size, the company does not have a remuneration committee as such.

3. Procedures

The following procedures implement the company's remuneration policy.

3.1. Performance evaluation procedures

The company implements an individual performance evaluation process for its employees. This process is conducted annually by the human resources department.

To complete this process, a written performance evaluation report is prepared by the collaborator's direct manager. For members of the Executive Committee, this report is written by the Chairman of the Board of Directors.

This report serves as a basis for the Executive Committee and the Board of Directors to award promotions and raises.

An evaluation report includes the following:

1. Identification
   Evaluation period, collaborator name, collaborator title, seniority level.

2. Role and Objectives
   Function and role of the collaborator during the period, objectives of the collaborator during the period.

3. Final performance and trajectory
   Overall performance attributed to the collaborator over the period and trajectory (upward, constant, downward) compared to the previous appraisal period. Performance can be:

   1. Don’t meet expectations : the collaborator does not meet the expectations at all;

   2. Meet some expectations : it meets certain expectations;

   3. Meet expectations: it meets all expectations;

   4. Exceed expectations : it meets all expectations and more;

   5. Substantially exceeds expectations : it goes far beyond all expectations.

4. Strengths and opportunities for improvement
   Lists the strengths the collaborator has demonstrated, as well as opportunities for improvement for the next evaluation period.

5. Details of performance item by item
   The company evaluates the performance of an collaborator on 3 levels:

   1. Added value
      The role of each collaborator is to produce value for the company. This position describes the value-added objectives that the company expects from the collaborator over the period.

   2. Client
      Every collaborator has a client, whether external or internal to the company. This position is used to evaluate the collaborator's performance towards this client.

   3. Team
      The collaborator works as part of a team within the company. This position is used to evaluate how the collaborator fits into the team and its culture.

3.2. Principles for remuneration of independent control functions

The control functions (compliance, risk management, internal audit) must operate independently. To this end, the structuring of remuneration plays a key role.

The following principles are observed for the remuneration of its functions:

1. Mostly fixed, little variable
   Remuneration should be predictable and known in advance to prevent harmful opportunistic behavior as much as possible. Thus, the majority of the remuneration should be a fixed salary agreed upon in advance.

2. Not linked to the company's financial performance
   The variable part of the remuneration cannot depend on the financial performance of the company, but only on the intrinsic performance of the employee in carrying out his control function.

3.3. Modification

The Board of Directors reserves the right to make changes to this remuneration policy and its procedures, within the limits of regulatory requirements.

3.4. Monitoring compliance with policies and procedures

The Board of Directors is responsible for enforcing this policy and implementing these procedures within the company.