Transparency towards staff and the public

  1. Banking Law: Article 75
  2. Delegated Regulation 575/2013: Articles 435 and 450
  3. Relevant thematic NBB circulars:
  4. International reference documents:

 

The institution’s strategies, policies and procedures should be communicated to all relevant staff throughout the institution. For further information, please refer to paragraphs 231 and 232 of Guidelines EBA/GL/2015/05.

As regards transparency towards the public, Article 75 of the Banking Law requires institutions to publish on their websites the relevant information contained in their governance memorandums, which should cover at least the information referred to in paragraph 234 of Guidelines EBA/GL/20121/05.

The disclosure of the risk management objectives and policies is regulated directly in Article 435 of Regulation No 575/2013. For each separate category of risk, the institution should publish a minimum of information. Furthermore, the said article indicates which information should be made public regarding governance arrangements.

The disclosure of information on the remuneration policy and practices is governed by Article 450 of Regulation No 575/2013. This involves a mix of qualitative and quantitative information regarding the remuneration policy, which should be updated annually by the institution.

Article 449a of Regulation No 575/2013 also provides that from 28 January 2022, large institutions[1] which have issued securities that are admitted to trading on a regulated market in a Member State, as defined in Article 4(1)(21) of Directive 2014/65/EU, should disclose information on environmental, social and governance risks, including physical risks and transition risks.

 

[1] As defined in Regulation No 575/2013.