Building on the overarching compensation principles included in Swiss Re’s Articles of Association, the compensation framework is captured within the Swiss Re Group Compensation Policy (the Compensation Policy). The Compensation Policy governs the compensation structure and processes across all functions and locations at Swiss Re and is reviewed regularly.
The Compensation Policy also contains guidance for the execution of individual compensation actions. The Compensation Committee has approved an authority matrix that defines the limits to which each level of management can authorise compensation payments. Separate limits apply to each compensation element, thereby ensuring that all payments receive the appropriate level of approval. The Group CEO or the Compensation Committee, as applicable, approves all compensation that exceeds the pre-set limits. The Group CEO is not involved in his own pay decisions.
The Human Resources function conducts a regular self-assessment of Swiss Re’s compliance with the Compensation Policy. The Compensation Committee reviews this self-assessment and identifies potential areas of improvement. The Compensation Committee receives reports on compensation decisions as appropriate, including a comprehensive review of the effectiveness of the annual compensation review cycle.
Swiss Re is required to assess the compliance of the Compensation Policy with the requirements of FINMA. As part of this process, the Board’s Finance and Risk Committee is required to review risks related to the Compensation Policy.
To facilitate the compliance certification process, a comprehensive risk analysis of the Compensation Policy is conducted on an annual basis.
To reflect best practices, the Compensation Policy prohibits the use of any personal hedging strategies or remuneration and liability-related insurance that could undermine the risk alignment effects and economic exposure embedded in compensation arrangements.