Remuneration policy for investment firms

This course provides an in-depth understanding of remuneration governance requirements applicable to Professionnels du Secteur Financier (PFS) in Luxembourg under CSSF Circular 10/437 and related regulatory standards. It aims to equip participants with the knowledge and tools to design, implement, and maintain compliant, transparent, and risk-aligned remuneration frameworks.

By the end of this training, participants will be able to:

• understand the scope and key principles of CSSF Circular 10/437 and other relevant EU remuneration regulations;
• clarify the respective responsibilities of the Board, senior management, and control functions in remuneration oversight;
• apply the principle of proportionality based on the size, risk profile, and complexity of the institution;
• distinguish between fixed and variable components of remuneration and understand regulatory limits and ratios;
• integrate risk, compliance, ex-post risk adjustments, and performance assessment metrics;
• ensure compliance with CSSF reporting, disclosure, and documentation obligations.

• Regulatory framework overview
• Governance and oversight responsibilities
• Proportionality principle and scope
• Structure of remuneration
• Risk alignment mechanisms
• Disclosure, transparency, and reporting

This training is coordinated by Julien Treffort and Vinciane Istace, Partners, and Elena Bunduchi, manager at PwC Luxembourg.

Vinciane Istace is a partner in the People, Experience and Change service team at PwC Luxembourg with over 30 years of experience. She has led the HR function at PwC, structuring operational capabilities and co-designing the firm’s HR strategy. Currently, she oversees the People and Process Outsourcing practice, providing clients with payroll, immigration, and HR administration support, as well as strategic HR advisory services. Vinciane combines deep HR technical expertise with extensive experience in fostering positive workplace interactions. She is also a diversity and inclusion leader, head of communication and PR, and a regular speaker at conferences, with notable projects including the EIB Gender Strategy Evaluability and university HR transformation initiatives.

Julien Treffort is a partner at PwC Luxembourg with expertise in personal taxation, social security, reward and compensation, pensions, and expatriate services. Since joining PwC in 2007, he has advised a diverse range of clients from financial and industrial sectors, assisting employers in structuring employment and compensation both locally and internationally. Julien specialises in designing incentive plans and supplementary pension schemes for key employees and provides tax consulting to self-employed individuals and private clients. He is an experienced speaker and trainer at the Luxembourg Life Long Learning Center, regularly delivering workshops and professional training sessions.

Elena Bunduchi is a manager with over seven years of expertise in Reward and HR Regulations, specialising in the design and implementation of remuneration and benefits, reward and regulatory compliance reviews, HR audits, and due diligence. She provides consultancy on Financial Sector remuneration regulations aligned with local laws and CSSF Circulars, including CRD-V, IFD, AIFMD/UCITS Directives, MiFID, and SRD II. Elena has conducted critical reviews of banking remuneration policies to assess compliance with CRD V and EBA Guidelines, supported a banking group in establishing its Luxembourg branch by aligning remuneration frameworks with group and regulatory standards, and contributed to Remuneration Policy Design. Her client projects include workshops on IFD application compliance, consultancy on regulatory and reward questions with CSSF experts, and advisory on CRR Pilar III disclosure reports such as Diversity and Remuneration policies. Her expertise encompasses reward and regulatory compliance review, employment legislation, compensation benchmarking, payroll, HR reporting, and audits.