The Cyprus Securities and Exchange Commission (CySEC) on June 2^nd, 2023, released Circular C576 regarding the adoption of the below guidelines issued by the European Banking Authority (EBA) on:

• benchmarking exercises on remuneration practices and the gender pay gap under Directive (EU) 2019/2034, and
• data collection exercises regarding high earners under Directive 2013/36/EU and under Directive (EU) 2019/2034.

Both guidelines are adopted by CySEC and incorporated into its supervisory practices and regulatory approach within the context of the prudential supervision framework. Cyprus Investment Firms (CIF) categorized as Class 2 under the IFR/IFD framework are required to disclose specific data about their remuneration practices and the employees identified as high earners.

A. EBA Guidelines on benchmarking exercises on remuneration practices and the gender pay gap.

CIF entities shall prepare and submit to CySEC by the 15^th of June of each calendar year, Annexes I-IV. More specifically,

• Annex I: General information and information on remuneration for all staff in investment firms,
• Annex II: Information on the remuneration of identified staff in investment firms,
• Annex III: Information on the remuneration of identified staff per business area, and
• Annex IV: Derogations to the application of the requirement to pay out a part of variable remuneration deferred and in instruments for investment firms.

In addition, a CIF shall prepare and submit to CySEC by the 15^th of June and every three years starting from 2024, Annex V of the same guidelines disclosing information on the gender pay gap.

B. EBA Guidelines on the data collection exercises regarding high earners

CIF entities must disclose data on the remuneration of high earners of the previous financial year by completing and submitting to CySEC Annexes I and II by the 15^th of June. In particular,

• Annex I: Information on the remuneration of high earners under Directive 2013/36/EU, and
• Annex II: Information on the remuneration of higher earners under Directive (EU) 2019/2034.

In the context of the said guidelines, a high earner is considered any staff member remunerated with at least EUR 1 million in the financial year. In the case of prudential consolidation, data shall be disclosed for all entities and branches included in the highest level of prudential consolidation. Otherwise, data shall be reported on an individual basis.

*CIF entities that do not identify any high earners to report are not required to submit this information.

C. The below table summarizes the reporting obligations under both sets of EBA Guidelines.

EBA Guidelines	Reporting obligation	Reference year	Deadline
Benchmarking exercises on remuneration practices and gender pay gap	Annexes I-IV	2022	31st of August 2023
	Annexes I-IV	2023 and every year onwards	15th of June 2024 and every year onwards
	Annex V	2023	15th of August 2024 and every three years onwards
Data collection exercises regarding high earners	Annexes I-II	2022	31st of August 2023
	Annexes I-II	2023 and every year onwards	15th of June 2023 and every year onwards

All data shall be prepared and submitted to CySEC through the CySEC XBRL Portal, which is expected to be updated accordingly by the end of June 2023.

If you require more information or support regarding the reporting of benchmarking data, gender pay gap data, and high earners data feel free to contact our Regulatory Compliance team by email at info@salvusfunds.com. We are always ready to answer your questions and support you in achieving regulatory compliance.

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