APRA Remuneration Website Disclosures
APS 330 Remuneration Disclosures
For the Year Ended 30 June 2023
Preliminary Note: Merger of Newcastle Permanent and Greater Bank
Newcastle Greater Mutual Group Ltd (NGM Group) (formerly known as Newcastle Permanent Building Society Limited (Newcastle Permanent)) completed a merger with Greater Bank Limited (Greater Bank) on 1 March 2023 (Merger Date) (Merger). The Merger involved a voluntary total transfer of all the business (including employees), assets, liabilities and members of Greater Bank to NGM Group on the Merger Date under the Financial Sector (Transfer and Restructure) Act 1999 (Cth).
On the Merger Date, the existing corporate entity of Newcastle Permanent changed its corporate name to “Newcastle Greater Mutual Group Ltd”. Since the Merger Date, NGM Group has operated as a single authorised deposit-taking institution under the Newcastle Permanent and Greater Bank brands.
As a result of the Merger, where appropriate, the qualitative disclosures below are provided separately for the period from 1 July 2022 to 28 February 2023 (i.e. for the period during the financial year ended 30 June 2023 before the Merger) and for the period from 1 March 2023 to 30 June 2023 (i.e. for the period during the financial year ended 30 June 2023 after the Merger).
| Qualitative Disclosures |
| (a) Information relating to the bodies that oversee remuneration: |
|
the name, composition and mandate of the main body overseeing remuneration; |
Refer to the Preliminary Note above. Period from 1 July 2022 to 28 February 2023 (i.e. the period before the Merger) For the period from 1 July 2022 to 28 February 2023 (i.e. for the period during the financial year ended 30 June 2023 before the Merger), the Remuneration and People Committee (R&P Committee) oversaw Newcastle Permanent’s (now known as NGM Group) remuneration framework, policies and practices. The R&P Committee was a committee of the Newcastle Permanent Board. It was a requirement of the R&P Committee’s Charter that the R&P Committee consist of not less than three members who were Non-Executive Directors of Newcastle Permanent, the majority of whom (including the Chair) were independent. It was also a requirement of the Charter that at least one member of the R&P Committee was also a member of the Newcastle Permanent Board’s Risk Committee. The following were members of the R&P Committee for the period from 1 July 2022 to 28 February 2023:
All of the above were, for that period, independent Non-Executive Directors of Newcastle Permanent. The role and responsibilities of the R&P Committee were outlined in the R&P Committee Charter and included the following in relation to remuneration:
Period from 1 March 2023 to 30 June 2023 (i.e. the period after the Merger) On completion of the Merger and effective from the Merger Date, the R&P Committee was replaced by a new NGM Group People, Culture and Remuneration Committee (PCR Committee). Since the Merger Date, the PCR Committee has overseen NGM Group’s remuneration framework, policies and practices. The PCR Committee is a committee of the NGM Group Board. PCR Committee members must be Non-Executive Directors of NGM Group. The PCR Committee must consist of not less than three members, all of whom must be independent. At least one PCR Committee member must be a member of the Board’s Risk Committee. For the period since the Merger Date to 30 June 2023, the members of the PCR Committee were:
The role and responsibilities of the PCR Committee are outlined in its Charter. The PCR Committee’s primary role is to assist the Board by providing objective review and oversight of people and remuneration related policies, frameworks and practices so that they:
The PCR Committee also assists the Board by overseeing and reviewing succession planning for NGM Group. Key remuneration related responsibilities of the PCR Committee include: People
Remuneration strategy
Remuneration Policy
Remuneration arrangements and outcomes
Performance framework, variable remuneration and benefits
Recognition
Remuneration disclosures
|
|
the name of external consultants whose advice has been sought, the body by which they were commissioned, and in what areas of the remuneration process; |
Refer to the Preliminary Note above. Period from 1 July 2022 to 28 February 2023 (i.e. the period before the Merger) NGM Group’s CEO engaged Ernst & Young to provide independent remuneration advice on the quantum and structure of remuneration for NGM Group’s Executives (excluding CEO remuneration). NGM Group’s People & Culture Division also engaged Ernst & Young to provide advice on (among other things) compliance with APRA Prudential Standard CPS 511 Remuneration (CPS 511). The R&P Committee engaged Guerdon Associates to provide independent remuneration advice on the quantum of the remuneration of NGM Group’s Executives. NGM Group’s Legal Division engaged Minter Ellison to review certain aspects of the Remuneration Policy to better align with CPS 511. The R&P Committee and Board engaged Guerdon Associates to provide independent remuneration advice on the quantum and structure of remuneration for NGM Group’s CEO.
NGM Group engaged Guerdon Associates to provide independent advice on the structure and quantum, including certain market comparisons, of Directors’ remuneration. |
|
a description of the scope of the ADI's Remuneration Policy (e.g. by regions, business lines), including the extent to which it is applicable to foreign subsidiaries and branches; and |
Refer to the Preliminary Note above. Period from 1 July 2022 to 28 February 2023 (i.e. the period before the Merger) The Newcastle Permanent Remuneration Policy applied to remuneration arrangements for Non-Executive Directors and Executives, being Newcastle Permanent’s Accountable Persons under the Banking Executive Accountability Regime (BEAR), other Responsible Persons (excluding the responsible auditor), risk management, compliance, internal audit and financial control personnel, all other employees for whom a significant proportion of their total remuneration is variable and determined by performance measures and certain third party service providers to Newcastle Permanent (such as the co-sourced internal audit services provider and mortgage brokers). Newcastle Permanent does not have any foreign subsidiaries or branches. Period from 1 March 2023 to 30 June 2023 (i.e. the period after the Merger) On the Merger Date the Remuneration Policy was updated for NGM Group in accordance with CPS 511 and applies to NGM Group. The Remuneration Policy also applies to persons who are:
The Remuneration Policy does not extend to Non-Executive Director remuneration, which is separately outlined in the NGM Group Constitution. NGM Group does not have any foreign subsidiaries or branches. |
|
a description of the types of persons considered as material risk takers and as senior managers as defined in paragraph 22 of APS 330, including the number of persons in each group. |
Refer to the Preliminary Note above. Period from 1 July 2022 to 28 February 2023 (i.e. the period before the Merger) For the period from 1 July 2022 to 28 February 2023, Newcastle Permanent's "senior managers" and “material risk takers” as defined in paragraph 22 of APS 330 comprised the following 11 personnel:
Newcastle Permanent does not consider any other employees to be “material risk takers”. Period from 1 March 2023 to 30 June 2023 (i.e. the period after the Merger) For the period from 1 March 2023 to 30 June 2023, NGM Group’s "senior managers" and “material risk takers” as defined in paragraph 22 of APS 330 comprised the following 12 personnel:
NGM Group does not consider any other employees to be “material risk takers”. |
|
(b) Information relating to the design and structure of remuneration processes: |
|
|
an overview of the key features and objectives of remuneration policy; |
Refer to the Preliminary Note above. Period from 1 July 2022 to 28 February 2023 (i.e. the period before the Merger) The principle objective of Newcastle Permanent’s Remuneration Policy was to support appropriate levels of remuneration while adhering to sound risk management and governance principles, through remuneration practices that are designed to:
Newcastle Permanent’s remuneration framework consisted of the following components:
Period from 1 March 2023 to 30 June 2023 (i.e. the period after the Merger) On the Merger Date, the Remuneration Policy was updated for NGM Group in accordance with CPS 511. The principal objective of the NGM Group Remuneration Policy is to support appropriate levels of remuneration necessary to attract, retain and motivate high quality people required to lead and manage the organisation, while adhering to sound risk management and governance principles. NGM Group’s Remuneration framework and practices are guided by and designed to:
NGM Group’s remuneration framework consisted of the following components:
In keeping with sound remuneration practice and to support NGM Group’s long-term financial soundness, the NGM Group PCR Committee and Board ensures that the payment methodology, assessment process and any performance based variable rewards are designed to align remuneration with prudent risk-taking and the outcomes of business activities. |
|
whether the Remuneration Committee reviewed the ADI's Remuneration Policy during the past year, and if so, an overview of any changes that were made; and |
Refer to the Preliminary Note above. Period from 1 July 2022 to 28 February 2023 (i.e. the period before the Merger) The R&P Committee considered the Remuneration Policy in October 2022 and recommended some updates to the malus and clawback provisions to better align the policy with CPS 511. The recommended amendments were subsequently approved by the Newcastle Permanent Board. Period from 1 March 2023 to 30 June 2023 (i.e. the period after the Merger) On the Merger Date, the organisation’s Remuneration Policy was replaced with a new policy that was appropriate for the larger merged organisation. In the lead up to completion of the Merger, the development of the new NGM Group Remuneration Policy was initially overseen and the new policy was reviewed by the combined Merger Advisory Board, which was an advisory forum that consisted of the eight Non-Executive Directors that ultimately comprised the NGM Group Board on completion of the Merger. The new Remuneration Policy was also reviewed and formally adopted by the NGM Group Board on the Merger Date. The new Remuneration Policy sets out how NGM Group designs, manages and operates its remuneration and reward arrangements to support attraction, retention and motivation of its employees. The purpose of the new policy is to:
|
|
a discussion of how the ADI ensures that risk and financial control personnel (as defined in CPS 510) are remunerated independently of the businesses they oversee. |
Refer to the Preliminary Note above. Period from 1 July 2022 to 28 February 2023 (i.e. the period before the Merger) The key risk and financial control personnel were defined in the Newcastle Permanent Remuneration Policy as the Chief Financial Officer, Chief Risk Officer, Company Secretary & General Counsel and Head of Internal Audit. These personnel were entitled to participate in Newcastle Permanent's Incentive Schemes, however, their key performance indicators (KPIs) and proportion of fixed to variable remuneration were structured so as not to compromise the independence of these individuals in carrying out their roles. This independence was also supported by the involvement of the relevant Committees and the Board in setting the objectives for, and assessing the performance of, the Chief Risk Officer, Company Secretary & General Counsel and Head of Internal Audit. Variable remuneration for risk and financial control personnel was paid where a clear contribution to successful outcomes for Newcastle Permanent was demonstrated and the individual attained and excelled against pre-agreed KPIs (financial and non-financial) during a performance cycle. Period from 1 March 2023 to 30 June 2023 (i.e. the period after the Merger) Under NGM Group, the risk and financial control personnel are defined in the Remuneration Policy as Employees whose primary role is in risk management, compliance, internal audit and financial control. These personnel were entitled to participate in legacy Newcastle Permanent or Greater Bank Incentive Schemes, however, their key performance indicators (KPIs) and proportion of fixed to variable remuneration were structured so as not to compromise the independence of these individuals in carrying out their roles. This independence was also supported by the involvement of the relevant Committees and the Board in setting the objectives for, and assessing the performance of, these personnel. Variable remuneration for risk and financial control personnel was paid where a clear contribution to successful outcomes for Newcastle Permanent or, where appropriate, Greater Bank, was demonstrated and the individual attained and excelled against pre-agreed KPIs (financial and non-financial) during a performance cycle. |
|
( c ) Description of the ways in which current and future risks are taken into account in the remuneration processes: |
|
|
an overview of the key risks that the ADI takes into account when implementing remuneration measures; |
Refer to the Preliminary Note above. Period from 1 July 2022 to 28 February 2023 (i.e. the period before the Merger) Newcastle Permanent took into consideration the key risks assessed and articulated in its organisational risk profile, Strategic Plan and Risk Appetite Statement when setting performance targets for the Organisational Performance Scorecard (which is also the CEO Scorecard) and the Executive Performance Scorecards and, measuring and assessing organisational and individual performance during the financial year. Period from 1 March 2023 to 30 June 2023 (i.e. the period after the Merger) There was no change to the key risks that NGM Group takes into account when implementing remuneration measures following the completion of the Merger. |
|
an overview of the nature and type of the key measures used to take account of these risks, including risks difficult to measure (values need not be disclosed); |
Refer to the Preliminary Note above. Period from 1 July 2022 to 28 February 2023 (i.e. the period before the Merger) Effective risk management and compliance management was assessed in the Performance Scorecards of the CEO and Executives between 1 July 2022 and 28 February 2023, as a Values and Risk modifier, by reference to the following quantitative and qualitative measures and taking a ‘Behaviours First’ approach to the assessment of performance:
Effective risk and compliance management is a gateway characteristic for a “Good” performance rating (and any associated incentive payment) for all staff across the organisation. This recognises the importance of risk and compliance management within every role, to support customer and industry expectations, long-term financial outcomes and the Risk Management Framework (including expected Risk Culture). Additionally, individual personnel throughout the organisation may have specific risk and compliance goals and measures incorporated in their personal KPIs as directly relevant to their area of responsibility. Period from 1 March 2023 to 30 June 2023 (i.e. the period after the Merger) Performance of the NGM Group CEO and Executives for the period of 1 March 2023 to 30 June 2023 was measured in the same manner as outlined above. |
|
a discussion of the ways in which these measures affect remuneration; and |
Refer to the Preliminary Note above. Period from 1 July 2022 to 28 February 2023 (i.e. the period before the Merger) For the CEO and Executives, the above mentioned Values and Risk modifier was applied through a mix of quantitative and qualitative assessments by the R&P Committee. Based on the recommendations of the R&P Committee and the decision of the Board, the CEO and Executives may receive all, part or no incentive payment. The R&P Committee considered information from the Audit Committee and Risk Committee regarding audit items and risk and compliance items respectively, arising during the financial year that may be relevant to the assessment of the CEO and each Executive’s performance and management of key risks. Employees would be excluded from participating in the Incentive Schemes or from receiving an incentive payment (as per the relevant scheme rules) where they failed to comply with risk management and compliance requirements measured by:
Where an individual’s performance objectives also included a specific risk or compliance KPI a weighting was attributed to that objective which, combined with the risk and compliance gateway, contributed to the outcome of the annual performance assessment process and calculation of any incentive payment. Ultimately, the CEO and/or the Board also retained the discretion to adjust the performance-based components of remuneration downwards, including to zero if appropriate, if such adjustments were necessary in certain situations including but not limited where an adjustment was required to:
Period from 1 March 2023 to 30 June 2023 (i.e. the period after the Merger) There was no change to the way these measures affected remuneration for NGM Group following the completion of the Merger. |
|
a discussion of how the nature and type of these measures has changed over the past year and reasons for the change, as well as the impact of changes on remuneration. |
Refer to the Preliminary Note above. Period from 1 July 2022 to 28 February 2023 (i.e. the period before the Merger) As discussed above, Newcastle Permanent employed a Values and Risk modifier to the performance assessment process for the CEO and Executives and a Risk and Behaviours gateway for all other employees. The Values and Risk modifier was used to modify the incentive outcomes for the CEO and Executives either upwards or downwards based on the degree to which risk objectives are met and their risk behaviours. The Values and Risk modifier (for CEO and Executives) and Risk and Behaviours gateway for all other staff reflected the strategic importance of risk management for Newcastle Permanent, as well as recommendations flowing from various industry and regulator reports, and were expected to encourage and incentivise positive risk behaviours and discourage poor risk behaviours through the adjustment of variable remuneration outcomes. Period from 1 March 2023 to 30 June 2023 (i.e. the period after the Merger) There was no change to the nature and or type of measures used to account for key risks for NGM Group following the completion of the Merger. |
|
(d) Description of the ways in which the ADI seeks to link performance during a performance measurement period with levels of remuneration: |
|
|
an overview of the main performance metrics for the ADI, top-level business lines and individuals; |
Refer to the Preliminary Note above. Period from 1 July 2022 to 28 February 2023 (i.e. the period before the Merger) The purpose of the Newcastle Permanent Staff Incentive Scheme and Executive Incentive Scheme (Incentive Schemes) was to reward actual achievement of an individual’s Balanced Scorecard outcomes (individual performance objectives) and for materially improved organisational performance. Performance-based variable remuneration (defined as incentive payments, retention payments and any other performance-based remuneration) under the Incentive Schemes was paid to eligible staff, Executives and the CEO where there was a clear contribution to successful outcomes for Newcastle Permanent and where the individual attains and excels against pre-agreed individual performance objectives (both financial and non-financial) during a performance cycle (as defined in their Balanced Scorecard). The employee must also comply with the risk management and compliance requirements and disciplinary requirements and must not engage in conduct that is contrary to the organisation’s values or risk appetite. For the 2023 Financial Year, the key KPIs cascaded through the CEO, Executive and individual performance objectives were broadly categorised into the following areas:
As discussed above, these metrics are overlaid by a Values and Risk modifier (for the CEO and Executives) and a Risk and Behaviours Gateway (for all other employees) to ensure that performance is only considered effective, and variable remuneration is only payable, where minimum risk and compliance behaviours, objectives and alignment to core values are met. Period from 1 March 2023 to 30 June 2023 (i.e. the period after the Merger) Following the completion of the Merger, the appointed NGM Group CEO and Executives received updated scorecards for the period of 1 March 2023 to 30 June 2023 which aligned to their role post-Merger and utilised the same principles as outlined above. All other Incentive Schemes (i.e. below the Executive) from both legacy Newcastle Permanent and Greater Bank remained unchanged for the performance year ending 30 June 2023 from those that were in place for the legacy businesses for the prior performance year. The Greater Bank Incentive Schemes (i.e. below the Executive) are set out below in section (f). |
|
A discussion of how amounts of individual remuneration are linked to institution-wide and individual performance; and |
Refer to the Preliminary Note above. Period from 1 July 2022 to 28 February 2023 (i.e. the period before the Merger) Newcastle Permanent’s organisational performance was assessed by reference to objectives set as part of the Strategic Roadmap and associated strategic and operational plans, which were incorporated into the Performance Scorecard as qualitative and quantitative measures and covered the broad categories referred to above. The Board assessed the organisation’s performance against this balanced scorecard, and on this basis, determined the maximum amount of the Incentive Scheme payment pool that would be made available. If organisational objectives are not met the Board could reduce the amount available for Incentive Scheme awards. Individual incentive amounts paid out of the Incentive Scheme payment pool were determined by reference to a matrix which considered Newcastle Permanent’s performance and individual performance outcomes as measured through the annual performance review process and calculated as a percentage of base salary. Period from 1 March 2023 to 30 June 2023 (i.e. the period after the Merger) There was no change to the way amounts of individual remuneration are linked to institution-wide and individual performance from the previous period (noted above) for NGM Group following completion of the Merger. |
|
A discussion of the measures the ADI will in general implement to adjust remuneration in the event that performance metrics are weak. |
Refer to the Preliminary Note above. Period from 1 July 2022 to 28 February 2023 (i.e. the period before the Merger) The Board retained discretion to adjust the performance-based components of remuneration downwards, including to zero if appropriate, if considered necessary in certain situations including but not limited to situations where an adjustment was required to:
Period from 1 March 2023 to 30 June 2023 (i.e. the period after the Merger) There was no change to the measures used in general to adjust remuneration in the event that performance metrics are weak for NGM Group following completion of the Merger. |
|
(e) Description of the ways in which the ADI seeks to adjust remuneration to take account of longer-term performance: |
|
|
a discussion of the ADI’s policy on deferral and vesting of variable remuneration and, if the fraction of variable remuneration that is deferred differs across persons or groups of persons, a description of the factors that determine the fraction and their relative importance; and |
Refer to the Preliminary Note above. Period from 1 July 2022 to 28 February 2023 (i.e. the period before the Merger) In accordance with BEAR requirements, for Newcastle Permanent all grants of variable remuneration to the CEO and Executives will be deferred for a minimum period of four years, subject to a $125,000 threshold. For all Executives, the amount of variable remuneration to be deferred for the four year period will be the lesser of:
where the minimum dollar threshold is triggered. Each year the Board will determine if the Executive has:
The R&P Committee and Board also undertook a formal and final assessment with respect of the deferred remuneration just prior to the time of its proposed payment. Period from 1 March 2023 to 30 June 2023 (i.e. the period after the Merger) For NGM Group, the variable remuneration for the following categories of employees will be subject to deferral:
The BEAR remuneration conditions include a minimum deferral amount (i.e. deferred variable remuneration) which is the lesser of:
|
|
A discussion of the ADI’s policy and criteria for adjusting deferred remuneration before vesting and after vesting through clawback arrangements.
|
Refer to the Preliminary Note above. Period from 1 July 2022 to 28 February 2023 (i.e. the period before the Merger) Under the Newcastle Permanent Remuneration Policy, the Board could determine that any variable remuneration (including deferred remuneration) of the CEO or an Executive be reduced or forfeited before the end of the deferral period as well as after any payment has occurred. These circumstances are classified as “malus” or “clawback” events. Examples of malus or clawback trigger events included, but were not limited to:
Malus and clawback provisions are applicable to any deferred payments for eligible leavers. Employees who are determined ‘ineligible leavers’ will forfeit any unpaid deferred remuneration. Clawback provisions may still apply to any variable remuneration paid to the employee prior to termination. Period from 1 March 2023 to 30 June 2023 (i.e. the period after the Merger) On the Merger Date the Remuneration Policy was updated for NGM Group in accordance with CPS 511. The Consequence Management Framework within the NGM Group Remuneration Policy is designed to assist NGM Group with aligning remuneration with risk and conduct matters. NGM Group also takes reasonable steps to ensure that, if variable remuneration may become payable to an Accountable Person of a subsidiary, the subsidiary complies with the deferred remuneration obligations as if the subsidiary were an ADI. Certain situations and Relevant Matters (as outlined in the Remuneration Policy and Consequence Management Framework) are considered for remuneration adjustment or clawback. Once a Relevant Matter has been identified it will be assessed and considered as to whether a remuneration variation is appropriate. NGM Group assesses Relevant Matters in terms of High, Medium and Low impact on two scales: the severity of the impact and the individual’s degree of accountability/responsibility for the Relevant Matter. |
|
(f) Description of the different forms of variable remuneration that the ADI utilises and the rationale for using these different forms: |
|
|
an overview of the forms of variable remuneration offered (i.e., cash, shares and share-linked instruments and other forms); and |
Refer to the Preliminary Note above. Period from 1 July 2022 to 28 February 2023 (i.e. the period before the Merger) Newcastle Permanent is not able to issue any shares or share-linked instruments. All variable remuneration is in the form of cash benefits. Period from 1 March 2023 to 30 June 2023 (i.e. the period after the Merger) NGM Group is not able to issue any shares or share-linked instruments. All variable remuneration is in the form of cash benefits. |
|
A discussion of the use of the different forms of variable remuneration and, if the mix of different forms of variable remuneration differs across persons or group of persons, a description of the factors that determine the mix and their relative importance. |
Refer to the Preliminary Note above. Period from 1 July 2022 to 28 February 2023 (i.e. the period before the Merger) The only variable forms of remuneration during the 2023 financial year were the:
Period from 1 March 2023 to 30 June 2023 (i.e. the period after the Merger) Following the completion of the Merger, the following Variable reward forms were adopted from Greater Bank, in addition to those referenced for the period 1 July 2022 to 28 February 2023:
|
|
Quantitative Disclosures |
|
(g) |
|
Number of meetings held by the main body overseeing remuneration during the financial year and the remuneration paid to its members. |
During the year, the R&P/PCR Committee met four (4) times. The total remuneration paid to Directors who were members of the Committee for part or all of the financial year is as follows:
* The total remuneration amount includes each Committee member’s annual Director fee and remuneration for all other roles, paid to them during the whole of the financial year. This is regardless of whether a Director was a member of the Committee for the whole or part of the financial year. |
|||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
|
(h) |
||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
|
The number of persons having received a variable remuneration award during the financial year. |
The table below presents the number of senior managers/ material risk takers who received a variable remuneration award, guaranteed bonuses, sign-on awards or termination payments during the financial year.
^ Amounts in the table above are disclosed in the financial year that the payment was received, and do not include deferred amounts which are disclosed in section (j) of this report.
|
|||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
|
(i) |
||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
|
Total amount of outstanding deferred remuneration, split into cash, shares and share-linked instruments and other forms. |
|
|||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
|
Total amount of deferred remuneration paid out in the financial year. |
|
|||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
|
(j) |
||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
|
Breakdown of the amount of remuneration awards for the financial year in accordance with Table 22A of APS 330. |
The table below presents the total value of remuneration awards for senior managers/material risk takers:
|
|||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
|
(k) |
||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
|
Quantitative information about persons' exposure to implicit and explicit adjustments of deferred remuneration and retained remuneration. |
NGM Group is not able to issue shares or share-linked instruments, so no payment is based on share values or implicit fluctuations. |
|||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||