• Code requires deferral of between 40% and 60% of bonus over a p • eriod of 3 to 5 years plus 50% of variable remuneration to be paid in shares or equivalent and held for a further retention period.
  • No FSA limit on proportion of fixed to variable remuneration or total amount paid.
  • Transitional provisions end on 1 July 2011.
  • Firms not previously caught by the Code may make payment of non-compliant bonuses in respect of 2010 if the firm has taken reasonable steps to implement the Code as soon as reasonably practicable and by no later than 1 July 2011.  
  • Code Staff should be notified as soon as possible that they are classified as Code Staff, and should be notified of the implications.  
  • Firms should refrain from offering guaranteed variable payments to any staff from 1 January 2011, without appropriate internal sign-off and only in exceptional circumstances.  
  • Deferred remuneration should be subject to malus provisions to take account of: subsequent poor performance by the individual; poor performance by the business entity; or breach of risk management by the entity.  
  • Firms should prepare a Remuneration Policy Statement recording self-assessment of Code compliance. This is to be filed with the FSA.  
  • Identify the correct proportionality tier for the firm, taking into account the highest tier company in the group.  
  • Review contracts of employment, bonus plans and share schemes to ensure these are Code compliant. This may require consultation with employees.  
  • Remember annual disclosure obligation, to be complied with by no later than 31 December 2011.