PGMN3 Pay: EBITDA Gate and ESG Bonus Metrics
Pague Menos (PGMN3) FRE compensation disclosure is a clean template for EBITDA-gated bonuses, scorecard metrics (including ESG for some directors), and equity vs cash mix for Board and statutory officers.
This page summarizes a remuneration analysis from the 2025 FRE. apicvm returns the filings.
The research question
> How is management pay structured, and which metrics gate the variable portion?
Policy backbone
- Remuneration Policy approved by the Board on 28 Jul 2023.
- Goals: align executives with the company, attract/retain talent, incentivize performance.
- Components: fixed (salary/fees + benefits), variable (bonus), and other elements the Board may set.
- People, Culture & ESG Committee advises; annual review; external consultants (e.g. Korn Ferry) may support.
Bonus design
| Design element | Disclosure |
|---|---|
| Eligibility | Mainly statutory and non-statutory directors; Board members do not receive variable pay |
| Score | Collective + individual goals → weighted grade |
| Grade bounds | When non-zero: min 70%, max 120% |
| Gate | EBITDA as habilitador |
| Collective metrics | Sales, Adjusted EBITDA, Same-Store Sales, Net Income, Operations & Expense Management |
| ESG | Some directors have diversity / ESG-agenda reporting metrics in the variable slice |
| Payout range | Currently 1 to 16× base salary |
Equity
- Eligible: independent Board members and statutory directors (per policy).
- Shares from treasury / buybacks — company states no dilution if grants are fully settled from that pool.
- 2025 snapshot cited: Board 9 members / 3 paid; Statutory Board 8 / 8 paid.
Mix example (FY ended 31 Dec 2024)
| Body | Mix |
|---|---|
| Board | Salary/fees 51% + share-based 49% |
| Statutory directors | Salary 35%, benefits 5%, bonus 18%, other variable 6%, share-based 36% |
Research takeaway
Compensation FRE sections are structured tables — route with name=Remunera instead of hoping embeddings preserve the EBITDA gate and 1–16× range.
Replicate with apicvm
export APICVM_KEY='apicvm_...'
export APICVM_URL='https://apicvm.dev'
curl -H "Authorization: Bearer $APICVM_KEY" \
"$APICVM_URL/v1/companies/resolve?query=PGMN3&by=ticker"
curl -H "Authorization: Bearer $APICVM_KEY" \
"$APICVM_URL/v1/documents?ticker=PGMN3&type=FRE&year=2025&name=Remunera"
curl -X POST -H "Authorization: Bearer $APICVM_KEY" \
-H "Content-Type: application/json" \
-d '{"callback_url":"https://your-server/callback","document":{"id":"<id>"}}' \
"$APICVM_URL/v1/document-text-extractions"Methodology note
Findings above come from a completed Hold analysis of the company's public 2025 FRE. This is a research illustration, not investment, legal, or tax advice. Verify numbers against the original filing before trading, modeling, or publishing reports.
Limitations
- apicvm returns filings and extracted text — it does not classify risks or compute coverage ratios.
- Figures are as of the FRE filing date; later ITRs or facts relevantes can update them.
- Corpus coverage depends on ingestion lag.
Next steps
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