Wage and Rewarding Policy

QNB Finansbank

Purpose

With this Wage and Rewarding Policy, the company aims to:

Define the Company’s wage system and practices as well as the principles and rules necessary to structure, monitor and check these practices.

Make the main wage parameters more transparent and provide employees with direct access to such parameters.

Lay out the main framework and core principles determining the wage structure for all employees.

Scope

The scope of the Wage and Rewarding Policy is described as follows: It applies to all QNB Finansfaktoring employees.

The company drafts, the Policies in alignment with the parent Bank and in accordance with market conditions and legal regulations, and applies them company-wide.

This policy covers fixed and variable wages for the entire work force, with a focus on employees engaged with tasks that are likely to impact the risk profile.

Core Principles

The company's wage policies are focused on performance, and are determined in alignment with the market dynamics, Company strategies and shareholders' interests. In order to guarantee an effective wage management, transparency and equality within the company, the core principles of Company Wage Policy are listed below:

* Transparent and open management

* Compliance with legislative framework

* Consideration of the skills, experience and knowledge as required by job descriptions

* Support for sustainable performance

* Compliance with market conditions

* Alignment with long-term Company goals and contribution to the effectiveness of risk management

Policy Management

Fixed wages are determined according to the role and the scope of responsibilities, and calculated by taking into account the requirements and experience sought for each position. For employees who are positioned according to the wage levels in the market, wage increase rates are determined according to inflation rates, employee performance and company policies.

Performance payments are made to employees if performance goals, determined in terms of both quantity and quality, are achieved. Performance measurements and payment systems avoid excessive focus on short term results, and rather look into parameters attributed to profitability and robust risk management to guarantee consistent performance in the mid- and long-term.

The wage to be paid to Board Members is determined pursuant to the Articles of Incorporation. The criteria for performance-based payments are as follows: The Senior Management of the Company determines and announces job descriptions and distributions as well as the criteria for performance payments of the employees.

The Wage and Rewarding Policy is periodically reviewed taking into account the market conditions and financial standing of the company.

The amounts of performance-based payments are not guaranteed in advance. Actions may be taken not to make performance-based payments due to incompliant behavior or behavior requiring disciplinary actions.

Previous year’s employee performance is assessed to determine whether or not a performance-based payment will be made. Wage systems should not in any way lead to risk-taking behaviors that exceed the Company's appetite for strategic risk.

In calculating performance, an appropriate combination of financial goals and non-financial performance goals is made.

Final Provision

The Wage and Rewarding Policy is an internal directive for the Company and does not constitute a right or obligation towards third parties.