Remuneration Policies in the Nordics

• In Nordics, remuneration policies contain limited pay disclosures. Instead, a more detailed treatment of pay practices is generally provided in the annual, backward-looking remuneration reports. 
• Generally vague policies across the Nordics may be largely in line with national implementations of SRD II. However, there are noticeable discrepancies between investor and non-investor sentiments, as evidenced in ISS annual benchmark policy surveys. For instance:
  • ISS surveys show siginficant discrepancies in investor and non-investor perceptions on how ESG metrics should be incorporated into executive compensation. For instance, a slight majority (52 percent) of investors said they believe ESG metrics should be incorporated into European executive compensation if the performance metrics are specific, measureable, and transparent. Only 27 percent non-investor respondents agreed. 
  • ISS surveys show significant differences in investor and non-investor sentiments regarding the scope and detail of derogation clauses. A signficant majority (60 percent) of investor respondents said derogation clauses should be clearly defined and limited, compared with only 20 percent of non-investor respondents that favored this approach. 
• Generally, the opportunity for remuneration policy overhauls in 2024 – stemming from the four-year policy cycle that began with the first implementation in 2020 – did not result in significant changes, with most remuneration policies remaining largely unchanged. 

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