Recoupments Policy v. 1.2

Recoupments Policy

 

SalMar Tenet

The job we do today is vital to the success of us all

CSRD Reference

G1 - Business Conduct 

Purpose

SalMar is committed to ensuring fairness and accountability in its remuneration practices. This policy outlines the conditions under which variable remuneration for senior personnel may be reduced, withheld, or terminated to protect the company’s integrity and interests. 

Scope

This policy applies to senior personnel, including but not limited to the Board of Directors and SalMar’s Executive Leadership Team. 

 

Governance and Accountability

Roles and Responsibilities

The Board of Directors holds ultimate responsibility for enforcing this policy. Executive management ensures that performance reviews and KPI assessments are conducted before any variable remuneration is paid. 

Managers and HR are responsible for implementing clawback provisions when conditions are met. Senior personnel must comply with contractual obligations and SalMar’s Ethical Guidelines. 

Monitoring and Reporting

Annual performance reviews at group and unit level, including KPI assessments, are carried out before payment of variable remuneration. Any decision to withhold or reclaim remuneration is documented and reported internally. 

 

Strategic Framework and Targets

SalMar enforces clawback provisions to maintain accountability and protect company interests. The company commits to applying these measures consistently and transparently in the rare case that requires this. 

Targets

SalMar enforces zero tolerance for misconduct that harms the Group’s interests. All variable remuneration decisions must comply with contractual terms and ethical standards. 

 

Operational Measures

Variable remuneration may be reduced, withheld, or terminated if it was incorrectly stated or if the individual acted in a way detrimental to SalMar. This includes damaging the company’s reputation, fraud, disclosure of confidential information, breach of employment contract, or violation of SalMar’s Ethical Guidelines. Decisions are based on documented performance reviews and KPI assessments.