Clawbacks/ Recoupments Policy v. 1.0

Arnarlax value:

We care!

Implementation:
Enforcement when necessary

Clawbacks/Recoupments Policy

Arnarlax can reduce or withhold and terminate variable remuneration for senior personnel. This group includes, but is not limited to, the Board of Directors and Arnarlax's Executive Leadership Team.

Detention or termination of variable remuneration would be on the basis of the remuneration having been incorrectly stated or that the employee has acted in such a way that it is to Arnarlax's detriment. This could include damaging Arnarlax's reputation, fraud, disclosure of Arnarlax's confidential information, breach of employment contract or Arnarlax's Ethical Guidelines, or other events.

An annual performance review at group and unit level, as well as an assessment of KPIs is carried out before payment of variable remuneration to senior personnel.