This Policy on the Process for Determining Compensation applies to all staff of the International Association of Credit Portfolio Managers (IACPM).

1. Review and approval.  The compensation of all staff members is reviewed and approved by the IACPM board of directors or, at the board’s discretion, a compensation committee of the board, provided that persons with conflicts of interest with respect to the compensation arrangement at issue are not involved in this review and approval.

2. Contemporaneous documentation and recordkeeping. There is contemporaneous documentation and recordkeeping with respect to the deliberations and decisions regarding the compensation arrangement.