The Board of Directors (Board) of ATS Finans AB adopts and updates remuneration provisions annually based on Finansinspektionen’s regulations (2011:1) applicable to credit institutions, investment firms and fund management companies licensed to conduct discretionary portfolio management.

The Board has considered the nature of Spotlight’s operations, as well as their scope and complexity when formulating the remuneration provisions. In an overall assessment, the board resolved that only fixed remuneration, both direct and indirect, shall be payable to all employees. Therefore, the company is restricted from entering agreements regarding variable remuneration and/or share-based incentive programmes. In addition, the Chairman of the Board, as a specially appointed member, shall, together with the company CEO, prepare the Board’s remuneration resolutions for the executive management, key individuals and employees that hold overarching responsibility for Spotlight’s control functions. However, the CEO shall not be involved in preparing the resolution regarding his/her remuneration. Furthermore, the remuneration provisions contain conditions governing payment of fixed remuneration. The conditions are deemed to prevent employees from taking risks in their work with the aim of increasing their fixed remuneration and adversely impacting the risk profile of Spotlight. Through the resolution that only fixed remuneration may be payable, and the fact that the Chairman of the Board is a specially appointed member, it is considered the company minimises employee’s monetary incentives from increasing Spotlight's risk profile. Generally, it is considered that the remuneration provisions promote sound and effective risk management, and mitigate excessive risk-taking in the operations.