Compensation
policy

Aciturri’s Compensation Policy for indirect staff is defined within the firm’s Role System.

The term “role” is defined as “the set of responsibilities, knowledge, and skills required for optimal performance of the tasks they are in charge of.” The same role may require different jobs with different technical content, depending on the area or department.

This compensation policy consists of four principles:

Internal equity

Direct connection between the assigned responsibilities for each role and the compensation received.

Competitiveness

It analyzes the relevant market with the aim of attracting and building loyalty from aciturri’s professionals.

Motivation

In addition to monetary compensation for a specific role, employees’ contribution to the achievement of results is openly acknowledged and, to the extent permitted by the law, to their own personal and/or family needs.

Flexibility

To quickly adapt to the market, the competition, and their own needs. When defining the compensation for each employee, several factors are taken into account: their role, their performance level, their potential, and their personal and family circumstances.

The fixed compensation for each role is defined according to the assessment of roles carried out by CompensaVal—a job rating tool developed by the firm Compensa Capital Humano.

It assesses seven factors: required training and experience; complexity of the problems; managerial tasks; leadership and motivation; decision-making; organizational responsibility; and nature of the results.

Assessment determines the combination between internal equity (80%) and market (20%) in order to maintain the internal equity as shown in the analy-
ses carried out and to improve competitiveness within the market.

The average for each of the different levels of content is calculated based on the formula for the fixed compensation market Median (MD):

Median (MD): Y = 90.117 * Points + 3,924.6

Based on this result, there are set limits for each level of content, being (-20%) the minimum and (+20%) the maximum. Then, the dispersion is divided by -20% and +20% in 9 different levels so the employees can receive compensation raises without having to change the content of their role according to their experience, performance and potential.

The compensation analysis is conducted based on the 16 roles applicable to our indirect staff which, for the purpose of this analysis, are arranged in 10 groups:

  • FUNCTIONAL SUPPORT: IT COMPRISES LEVELS 1 AND 2 OF FUNCTIONAL SUPPORT ROLES

  • TECHNICAL SUPPORT

  • LEVEL-1 ENGINEERING TECHNICIANS

  • LEVEL-2 ENGINEERING TECHNICIANS

  • LEVEL-3 ENGINEERING TECHNICIANS

  • LEVEL-1 CORPORATE TECHNICIANS

  • LEVEL-2 CORPORATE TECHNICIANS

  • LEVEL-3 CORPORATE TECHNICIANS

  • MANAGEMENT: THESE ROLES INCLUDE PRODUCTION MANAGER,FUNCTIONAL MANAGER, BUSINESS SUPERVISOR, AND FUNCTIONAL SUPERVISOR.

  • MANAGERIAL ROLES

The following table shows the fixed compensation details for 451 employees based in different locations and in charge of different technical tasks. Salary ranges are the same, regardless of the location.

2022 Breakdown Analysis

Men
LEVELINCLUDED ROLESOCCUPANTSAVERAGE SENIORITYAVERAGE AGEAVERAGE FIXED WAGE - €
LEVEL 1
FUNCSUPP 1
-
-
-
-
LEVEL 2
FUNCSUPP 2 / TECHSUPP
-
-
-
-
LEVEL 3
CORTECH 1 / ENGTECH 1
45
2
30
26,282
LEVEL 4
PLANNER
10
10
40
36,580
LEVEL 5
CORTECH 2 / ENGTECH 2
106
9
41
35,217
LEVEL 6
CORTECH 3 / ENGTECH 3
46
12
46
46,071
LEVEL 7
PROMA / FUNCMA / FUNCEXP
43
16
47
48,758
LEVEL 8
BUSMA / FUNCSUP / TECHEXP
25
15
46
55,245
LEVEL 9
BUSSUP / SUPEREXPERT
10
14
47
68,460
LEVEL 10
DIRECTOR
12
17
51
97,296

2022 Breakdown Analysis

Women
LEVELINCLUDED ROLESOCCUPANTSAVERAGE SENIORITYAVERAGE AGEAVERAGE FIXED WAGE - €
LEVEL 1
FUNCSUPP 1
8
6
40
23,839
LEVEL 2
FUNCSUPP 2 / TECHSUPP
12
14
42
26,466
LEVEL 3
CORTECH 1 / ENGTECH 1
28
7
37
27,527
LEVEL 4
PLANNER
5
12
37
30,659
LEVEL 5
CORTECH 2 / ENGTECH 2
51
10
40
33,517
LEVEL 6
CORTECH 3 / ENGTECH 3
16
15
48
41,792
LEVEL 7
PROMA / FUNCMA / FUNCEXP
21
15
43
51,453
LEVEL 8
BUSMA / FUNCSUP / TECHEXP
7
18
47
63,637
LEVEL 9
BUSSUP / SUPEREXPERT
2
14
51
60,481
LEVEL 10
DIRECTOR
4
20
50
90,222

2022 Comparative Analysis

Men - Women
levelincluded
roles
MEN AVG
FIXED WAGE - €
WOMEN AVG
FIXED WAGE - €
GLOBAL AVG WAGE - €AVG WAGE
WOMEN VS MEN
AVG WAGE
WOMEN’S VS GLOBAL
AVG WAGE
MEN’S VS GLOBAL

level 1

FUNCSUPP 1

-

23,839

-

-

-

-

level 2

FUNCSUPP 2 / TECHSUPP

-

23,839

-

-

-

-

level 3

CORTECH 1 /
ENGTECH 1

26,828

27,527

27,096

2.61%

1.59%

-0.99%

Level 4

PLANNER

36,580

30,659

34,606

-16.19%

-11.41%

5.70%

Level 5

CORTECH 2 / ENGTECH 2

35,217

33,517

34,665

-4.83%

-3.31%

1.95%

Level 6

CORTECH 3 /
ENGTECH 3

46,071

41,792

44,966

-9.29%

-7.06%

2.46%

Level 7

PROMA / FUNCMA / FUNCEXP

48,758

51,453

49,642

5.53%

3.65%

-1.78%

Level 8

BUSMA / FUNCSUP / TECHEXP

55,245

63,637

57,081

15.19%

11.49%

-3.22%

Level 9

BUSSUP / SUPEREXPERT

68,460

60,481

67,130

-11.66%

-9.90%

1.98%

Level 10

DIRECTOR

97,296

90,222

95,527

-7.27%

-5.55%

1.85%

Average wages by role 2018-2022 (€)

In accordance with the Remuneration Policy, and analyzing the data at an individual level within each group, it is shown that there is no difference in remuneration based on gender, geographic location, or any other factor that could be considered discriminatory. In fact, the differences in the average remuneration reflected in the table above are exclusively due to different levels of seniority, year of access to the role (the role system was established in 2012, since then the change of role occurs according to the increase in responsibilities) or depth of the position (the same job position has different depth depending on the volume of turnover managed, the associated responsibility and the number of people in the team, which marks different positions in the remuneration level within the same role).

In the case of direct personnel, salaries are determined by the applicable collective bargaining agreement (Chemical Industry Collective Bargaining Agreement, Seville Iron and Steel Industry Collective Bargaining Agreement, Valladolid Iron and Steel Industry Collective Bargaining Agreement, Burgos Iron and Steel Industry Collective Bargaining Agreement or Álava Iron and Steel Industry Collective Bargaining Agreement). On these, the Production-based Incentive System is applied, the same for all work centers, except in the Metal centers where the same variable system is applied as for indirect labor.

Thus, the compensation of direct personnel is determined by the salary concepts of the collective bargaining agreement, bonuses based on job position or coordination responsibility and incentives.

In the agreements that include professional groups, all jobs are associated with one of them. Hence, the compensation assigned to each group is the one received by anyone with a post within that group, regardless of who they are. In the agreements that include professional categories, these are determined by the evaluation from Skill Matrix and are also independent of the person holding the post.

Therefore, the fixed compensation for similar posts with the same level of experience and seniority is identical, regardless of any other factor (including age or gender). The variable compensation (incentive system) is directly linked to the employee’s performance, regardless of any other variables.

In the case of the Board of Directors, the remuneration of the members is regulated by Aciturri's Articles of Association: the position of administrator shall be remunerated and the remuneration system and the remuneration concept to be received by administrators who are not executive advisors, in the event that the administrative body takes the form of the Board of Directors, shall be a fixed annual allowance, appropriate to their services and responsibilities, which may be paid in cash and/or in kind.

Specifically, in 2022, the average remuneration of the Board Members 22 was €45,242.35 gross per year (all of them are men). No payments in kind were made during the year.

No contributions have been made to pension funds or plans in favor of the directors or Aciturri's management personnel, nor have any obligations been incurred for these items. The directors have not received any remuneration in the form of profit sharing, life insurance premiums or payments to long-term savings systems. Neither have they received any shares or stock options during the year, nor have they exercised any options, nor have they exercised any options pending execution, nor have they been granted any advances or loans. No indemnity payments have been made.


22. Disaggregated information on executive compensation is not included, since only one executive, the General Manager, is considered, and therefore the dissemination of this information would violate data protection.

the compensation of our direct employees is determined by the salary established in the collective agreements, plus incentives and bonuses according to the job or managerial responsibilities.