BROM's Remuneration policy presents the general framework and basic principles for determining the remuneration and is aligned with the applicable labour legislation, with the Collective Labour contract and with the provisions of NBR Regulation 5/2013.

The remuneration policy is deemed appropriate for the size and organization of the Bank, as well as for the nature, range and complexity of its business activities.

By applying the Remuneration policy, the Bank aims at retaining and leveraging employees of the highest professional, educational and moral calibre - qualities which generate added value for the Bank and its subsidiaries, motivating and encouraging its staff and that of the subsidiaries, so as to optimize individual and collective work-related performance, consolidating a culture of objective evaluation of endeavour and reward for performance, ensuring consistency between remuneration and the business strategy, risk policy, values and long-term targets of the Bank and of its subsidiaries.

The remuneration policy is aligned to the current business strategy, particularly regarding issues of principles and values, conduct and risk assumption policy and observes principles that seek to harmonize the individual interests of the Senior Managers and of the employees with the Bank's and its subsidiaries' business targets, especially on a long-term basis, through the evaluation of performance over time.

The policy allows and promotes a healthy and effective risk management, without encouraging risk taking which exceeds the risk tolerance level, thus preventing incentives granting for excessive risk taking and for other behaviors contrary to the interests of the credit institution.

The policy covers the personnel from all levels of the organizational structure (including the members of the management body) within the Bank and represents the framework for the remuneration policies of the Bank's subsidiaries.

The principles of the remuneration policy cover both the fixed component and the variable component of the remuneration of the entire personnel.

The members of the personnel are remunerated or receive rights associated with the variable remuneration, including the deferred part of the variable remuneration, only if the variable remuneration is sustainable in accordance with the Bank's overall financial situation and if it can be justified according to the performance of the Bank, of the structure where the employee's activity is carried out and of the individual performance of the respective employee.

The evaluation criteria refer to both individual and collective performance, specifically for a length of time sufficient to indicate real performance, as well as evaluation of individual performance during the period concerned, not only under financially measurable criteria but also under qualitative criteria, including, but not limited to, knowledge of the field of work, managerial skills, efficiency and general professional conduct, level of interest in and contribution to the work produced, compliance with the Bank's policies and so on.

The personnel remuneration consists of the following components:

A. Financial component, which includes the Fixed remuneration, meaning the base salary/ indemnity taking into consideration the local market conditions, the level of expertise and experience as well as individual performance in case a relevant evaluation has taken place, and the Variable remuneration, which is granted for achieving the objectives and depends on the achievement of BROM goals, as well as based on the evaluation of the financial and non financial performance criteria. Variable remuneration may include bonuses, rewards and other benefits.

The fixed and variable components of the total remuneration will be properly balanced, the fixed component representing a sufficiently high proportion of the total remuneration to allow the implementation of a flexible policy regarding the components of variable remuneration.

The level of the variable part of the remuneration of the identified personnel is established as a maximum percentage from the level of the total annual remuneration, depending on the performance and the results obtained as compared to the assigned objectives, correlated with the risk taking level, with the potential impact of the risk on medium and long term and with best practices in the field.

The annual objectives established by the Board of Directors, through the Bank's Business Strategy, will be correlated with specific indicators, as they are stipulated in the Strategy regarding significant risks management and other relevant strategies and policies, in order to discourage the excessive risk taking.

The bonuses granted to the identified personnel, depending on the rating obtained at the annual performance evaluation will comprise an immediate component representing a percentage out of the total granted bonus, which will be paid in the year following the year for which the evaluation was done, after the approval of the financial year statements and a deferred component representing the remaining bonus that will be paid in 3 years from the granting of the immediate component.

During the period of deferral, there will be a yearly performance assessment made for the specific activity for which the variable remuneration has been granted, in line with the bonus schemes and the overall financial performance of the bank.

The Bank has the right to adjust the bonus granted to an employee in the identified personnel category, depending on the performance.

B. Non-financial component, which may include different non-financial instruments, depending on the financial results of the Bank and according to the policies of the Bank.

The implementation, review and amendment of the remuneration policy are monitored by the Bank's Committee for Nomination and Remuneration.

The remuneration policy is assessed, in respect of its implementation, by the competent Regulatory and Supervisory Authorities.