Article 4 Remuneration policies for all staff

they are consistent with the rights and interests of holders of tokens with a view to ensuring that holders are treated fairly and that their interests are not impaired by the remunerationmeans all forms of fixed and variable remuneration, including the following:monetary or non-monetary payments and benefits, awarded directly to staff by or on behalf of issuers of asset-referenced tokens or e-money tokens in exchange for professional services provided by staff;carried interest payments within the meaning of Article 4(1), point (d), of Directive 2011/61/EU;other payments made via methods and vehicles which, if they were not considered as remuneration, would lead to a circumvention of the remuneration requirements set out in Regulation (EU) 2023/1114 and in this Regulation. practices adopted by the issuermeans a natural or legal person, or other undertaking, who issues crypto-assets;;

they are gender-neutral and based on the principle of equal pay for male and female staffmeans all employees of an issuer of asset-referenced tokens or e-money tokens, and all members of such issuer’s management bodies; for equal work or work of equal value within the meaning of Article 3(1), point (65), of Directive 2013/36/EU;

they are consistent with the objectives of the business and risk strategy, including environmental, social and governance (ESG) risk-related objectives, corporate culture and values, risk culture and risk appetitemeans the aggregate level and types of risk that an issuer of asset-referenced tokens or e-money token is willing to assume within its risk capacity, in line with its business model, to achieve its strategic objectives;;

they ensure that the staffmeans all employees of an issuer of asset-referenced tokens or e-money tokens, and all members of such issuer’s management bodies; engaged in control functionsmeans a function that is independent from the business units it controls and that is responsible for internal control procedures and includes the risk management, compliance and the internal audit functions; are remunerated in accordance with the achievement of the objectives linked to their functions and independently of the performance of the business areas they control;

they are consistent with the management of ESG risks and provide for incentives for the control and limitation of ESG impacts caused by the issuermeans a natural or legal person, or other undertaking, who issues crypto-assets;’s business activities;

they do not create a conflict of interest or incentive that may lead staffmeans all employees of an issuer of asset-referenced tokens or e-money tokens, and all members of such issuer’s management bodies; members to favour their own interests or the issuermeans a natural or legal person, or other undertaking, who issues crypto-assets;’s interests to the potential detriment of any holder of significant tokens they issue;

they do not encourage risk-taking that exceeds the level of risk appetitemeans the aggregate level and types of risk that an issuer of asset-referenced tokens or e-money token is willing to assume within its risk capacity, in line with its business model, to achieve its strategic objectives; of the issuermeans a natural or legal person, or other undertaking, who issues crypto-assets;;

they are available to the staffmeans all employees of an issuer of asset-referenced tokens or e-money tokens, and all members of such issuer’s management bodies; concerned at all times;

they are transparent to all staffmeans all employees of an issuer of asset-referenced tokens or e-money tokens, and all members of such issuer’s management bodies; regarding the fixed remunerationmeans all forms of fixed and variable remuneration, including the following:monetary or non-monetary payments and benefits, awarded directly to staff by or on behalf of issuers of asset-referenced tokens or e-money tokens in exchange for professional services provided by staff;carried interest payments within the meaning of Article 4(1), point (d), of Directive 2011/61/EU;other payments made via methods and vehicles which, if they were not considered as remuneration, would lead to a circumvention of the remuneration requirements set out in Regulation (EU) 2023/1114 and in this Regulation., processes and criteria for setting the variable remunerationmeans all forms of fixed and variable remuneration, including the following:monetary or non-monetary payments and benefits, awarded directly to staff by or on behalf of issuers of asset-referenced tokens or e-money tokens in exchange for professional services provided by staff;carried interest payments within the meaning of Article 4(1), point (d), of Directive 2011/61/EU;other payments made via methods and vehicles which, if they were not considered as remuneration, would lead to a circumvention of the remuneration requirements set out in Regulation (EU) 2023/1114 and in this Regulation. and the award criteria used;

they are clear, well documented, transparent, proportionate to the size, internal organisation and nature, as well as to the scope and complexity of the issuermeans a natural or legal person, or other undertaking, who issues crypto-assets;’s business activities.