Remuneration System

The Northmill Group (“Northmill” or “the Company”) applies a remuneration model designed to attract and retain competent employees while promoting sustainable performance and sound risk-taking. The remuneration policy is structured to align with Northmill’s strategic goals, shareholder interests, and effective risk management. Remuneration is individually determined to encourage performance in line with the Company’s values and long-term objectives.

The Company primarily applies fixed remuneration, supplemented by pension benefits and other incentives. The remuneration model is designed to be competitive yet balanced, ensuring financial stability while motivating employees.

Northmill’s remuneration system is structured to support sustainable growth and responsible risk-taking. By prioritizing fixed remuneration and ensuring that incentives align with strategic goals, the Company fosters a performance-driven culture that benefits employees, customers, and shareholders alike.

Fixed remuneration constitutes the primary component of Northmill’s remuneration system. It reflects the complexity of the role, individual performance, and prevailing market conditions. Additionally, pension benefits are offered according to industry standards and local regulations. Employees may also receive additional benefits, such as on-call compensation, depending on their roles.

Certain employees in specific positions may receive commission-based compensation, which is linked to quantitative targets. This form of remuneration is not classified as variable remuneration under the regulations of the Swedish Financial Supervisory Authority (Finansinspektionen).

Northmill does not currently apply variable remuneration. If variable remuneration were to be introduced, it would be linked to predefined role-specific, unit, and company-wide objectives to ensure that it contributes to responsible risk-taking and sustainable business development. The Board of Directors would decide on any variable remuneration based on Northmill’s financial position and capital requirements.

A specially appointed Board member oversees remuneration matters and ensures an independent evaluation of the policy and its application. This member, supported by the Company’s control functions, assesses remuneration structures and ensures compliance with Northmill’s strategic and regulatory obligations.

The Board of Directors has adopted a remuneration policy applicable to all employees, based on regulatory frameworks such as Article 450 of Regulation (EU) No. 575/2013 (CRR) and (EU) No. 2021/923, the Swedish Financial Supervisory Authority’s regulations (FFFS 2011:1 & 2014:12), and the European Banking Authority’s guidelines on sound remuneration policies (EBA/GL/2021/04).

The policy is grounded in a comprehensive risk analysis to ensure that the remuneration structure does not lead to excessive risk-taking. Employees whose roles significantly impact the Company’s risk profile are specifically identified within the framework of this policy.

The Board is responsible for establishing the overall remuneration structure, including any potential variable remuneration. The CEO determines the allocation of fixed remuneration in accordance with the Board’s guidelines. Northmill does not engage external consultants in the development of its remuneration policy.

Northmill integrates risk management principles into its remuneration structure. The fixed remuneration model minimizes the risk of incentives that could lead to excessive risk-taking. Furthermore, the Company’s long-term financial stability is considered in all remuneration decisions, ensuring that compensation does not compromise capital adequacy or operational resilience.

For employees in control functions, remuneration is structured to maintain their independence and objectivity. No employees in control functions currently receive variable remuneration.

Northmill’s independent control functions conduct annual evaluations of the implementation of the remuneration policy. The compliance function is responsible for ensuring adherence to regulatory frameworks and internal policies and reports its findings to the Board of Directors.