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BFSI Chronicle, 2 Annual Issue, 10  Edition July 2022
                                                                nd
                                                                                th
             Variable pay Components aligned               instruments in the Variable Pay in case
             effectively with Prudent Risk-taking to       the Variable Pay contains Share-linked
             ensure that Compensation is adjusted          Instruments. The Variable Pay should be
             for all Types of Risks, the Compensation      truly and effectively variable and can be
             outcomes  are  Symmetric  with  Risk          reduced to Zero Based on performance
             Outcomes, Compensation Pay-outs are           at an individual, business unit, and
             sensitive to the time horizon of the Risks,   company-wide level.
             and the Mix of Cash, Equity and other         In order to do so, performance measures
             forms of Compensation are Consistent          and their relation to Remuneration
             with Risk Alignment.                          Packages should be clearly defined
                                                           at  the  beginning  of  the  Performance
          b)   Composition of Fixed Pay: All the fixed
             items of Compensation, including the          Measurement Period to ensure that
                                                           the  Employees  Perceive  the  Incentive
             Perquisites and Contributions towards
             Superannuation / Retrial benefits,            Mechanism.
             may be treated as Part of Fixed Pay. All   c) Deferral of Variable Pay: Not all the
             Perquisites that are Reimbursable may         variable pay awarded after Performance
             also be included in the Fixed Pay so          Assessment may be paid immediately.
             long as there are Monetary Ceilings on        A certain portion  of Variable Pay, as
             these Reimbursements. The Monetary            decided by the Board of the Company,
             Equivalent of Benefits of Non-monetary        may be deferred to the Time Horizon
             nature (such as a Free Furnished House,       of the Risks. The portion of the deferral
             use of a Company Car, etc.) may also be       arrangement may be made applicable for
             part of Fixed Pay.                            both Cash and Non-cash Components of
                                                           the Variable Pay. The deferral period for
        Principles for Variable Pay:                       such an arrangement may be decided by
          a) Composition of Variable Pay: The              the Board of the Company.
             Variable Pay may be in the form of        d) Control and Assurance Function
             Share-linked instruments or a mix of          Personnel: KMPs and Senior
             Cash and Share-linked instruments. It         Management engaged in financial
             shall be ensured that the Share-linked
                                                           control, risk management, compliance,
             instruments conform with relevant             and Internal Audit may be compensated
             Statutory Provisions.
                                                           in a manner that is independent of the
          b) Proportion: The Proportion of variable        business areas they commensurate and
             pay in Total Compensation (Total              supervise  with  their  vital  role  in  the
             compensation includes fixed and variable      company. Accordingly, such personnel
             pay) needs to be Commensurate with            may have a higher proportion of fixed
             the Role and Prudent Risk-taking the          compensation. However, a reasonable
             Profile of KMPs / Senior Management.          proportion of compensation may be
             At Higher levels of Responsibility, the       in the form of variable pay, so that
             proportion of variable pay needs to be        exercising the options of malus and/
             higher. There should be a proper balance      or clawback, when warranted, is not
             between the Cash and Share-linked             rendered infructuous.



                                                                The Institute Of Cost Accountants Of India

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