富而德律师事务所：2024年薪酬管理中的ESG因素调研报告（英文版）

Arguments continue as to whether or not it is mandatory under the law to include sustainability aspects as a factor in management remuneration in Germany. Changes to the German Stock Corporation Act (as part of the implementation of the EU’s Second Shareholder Rights Directive or SRD II) suggest that, at a minimum, ESG factors need to be taken into account. On the other hand, based on the explanatory notes of the legislative draft, it can be argued that there is no strict obligation under the