Remuneration policies
Practical guidance for preparing this disclosure. Use this card to identify datapoints, verify claims and organise supporting evidence. For exact requirements, always refer to the official GRI source.
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This disclosure asks an organisation to explain the main features of its remuneration policies, in plain terms. The focus is on how pay is set and governed, rather than on listing every individual salary. A useful report will describe the policy approach, who it applies to, and the main principles or criteria used to determine pay and any related rewards.
Practically, the emphasis is on giving a clear picture of the organisation’s pay framework across the business, not just at a few headline sites or for a small group of senior people. Readers should be able to understand whether the policy is applied consistently, how it is overseen, and what parts of the organisation it covers.
* This LRA educational guidance supports disclosure preparation. For the exact requirements, always refer to the official GRI source.
A quick mental checklist before you prepare this disclosure — tick each as you settle it.
| Datapoint | What to capture | Evidence hint | Owner |
|---|---|---|---|
| Base pay policy | The rules and approach used to set fixed salary or fee amounts for the board and top executives, including how those amounts are determined and applied. | Remuneration policy, pay framework, committee papers, approved salary/fee schedules, contracts or appointment letters. | Reward / HR / Company Secretariat |
| Incentive pay policy | The rules for performance-linked pay for the board and top executives, including how awards are earned, measured and paid. | Remuneration policy, annual incentive plan rules, long-term incentive plan documents, committee minutes, award letters. | Reward / HR / Finance / Company Secretariat |
| Joining bonus policy | The approach to any one-off payments used to attract or recruit board members or senior executives, including when they are offered and under what conditions. | Offer letters, recruitment approval papers, remuneration policy, committee minutes, onboarding records. | Reward / HR / Talent Acquisition / Company Secretariat |
| Exit payment policy | The rules for any payments made when a board member or senior executive leaves, including how such payments are approved and calculated. | Termination agreements, settlement documents, remuneration policy, committee approvals, legal correspondence. | HR / Legal / Reward / Company Secretariat |
| Recovery policy | The approach to taking back previously awarded pay from board members or senior executives when the organisation applies a recovery mechanism. | Remuneration policy, clawback or malus provisions, committee minutes, award terms, recovery notices. | Reward / Legal / Company Secretariat |
| Pension and retirement | The retirement-related benefits available to the board and top executives, including pension arrangements and any other post-employment benefits covered by the policy. | Pension plan documents, benefit schedules, employment contracts, remuneration policy, committee papers. | HR / Reward / Pensions / Company Secretariat |
| Pay and performance link | How pay decisions for the board and top executives are tied to their goals and results in managing the organisation’s effects on the economy, environment and people. | Remuneration policy, performance scorecards, ESG or impact KPIs, committee papers, annual performance reviews. | Reward / Sustainability / HR / Company Secretariat |
Show GRI 2-19 sub-elements (LRA working checklist)
- Set out how pay arrangements for the board and senior leaders link their goals and results to how the organisation manages its economic, environmental and social impacts.
- Set out the pay arrangements for the board and senior leaders, including any pay that can be taken back.
- Set out the pay arrangements for the board and senior leaders, including any salary that is not variable.
- Set out the pay arrangements for the board and senior leaders, including pension or other retirement-related benefits.
- Set out the pay arrangements for the board and senior leaders, including any joining bonus or hiring incentive.
- Set out the pay arrangements for the board and senior leaders, including any payment made when employment ends.
- Set out the pay arrangements for the board and senior leaders, including any performance-linked pay.
LRA working checklist - paraphrased; see official source
- Set the reporting boundary first: confirm which people are covered, namely the board-level group and the senior leadership team, so the disclosure is prepared for the right population.
- List the pay elements you need to explain, using plain internal labels for each one: base salary, performance-linked pay, joining or recruitment incentives, exit-related payments, recovery or repayment provisions, and post-employment benefits.
- Gather the source material that supports each part of the explanation, such as pay policy papers, committee papers, approval records, contracts, and any other internal documents that show how the arrangements work.
- Draft the disclosure in two parts: first, explain the policy for each pay element; second, explain how those policies connect to the leaders’ goals and results, including how they link to the organisation’s handling of its economic, environmental and social impacts.
- Record any gaps, exclusions, or wording changes clearly, so it is obvious what has been included, what has not, and whether the final wording differs from the underlying source material.
- Check the finished text against the official source before sign-off, to make sure every required pay element and the performance link are covered accurately and nothing has been missed or overstated.
Translate the disclosure into an internal business question — then adapt it to your organisation's own language.
Use your organisation’s own labels first, then map them to the reporting wording. For example, use your internal terms for directors, senior leaders, base pay, bonus, long-term incentives, joining awards, exit terms, recovery clauses and pension arrangements. Keep the request in the language used by the pay, reward or board papers team.
Please provide the GRI 2-19 remuneration policies disclosure for the highest governance body and senior executives, including fixed pay, variable pay, sign-on bonuses, termination payments, clawbacks, retirement benefits, and the link to objectives and performance in relation to the management of the organisation’s impacts on the economy, environment and people.
Please send the current pay policy summary for [board members / senior leaders] covering [period]. Include base pay, bonus or incentive pay, joining awards, exit terms, recovery clauses and pension arrangements, plus a short note on how pay outcomes connect to performance measures and impact priorities. Please attach the source papers or policy documents and note the scope, version and approval date.
Formal email template
Subject: Request for executive pay policy details and supporting evidence for [reporting period] Hi [name/team], We are preparing the sustainability reporting pack and need a short summary of the pay arrangements for [board members / senior leaders / other covered group] for [reporting period]. Please send: - a plain-language summary of how base pay, variable pay, joining awards, exit terms, recovery clauses and pension arrangements are set; - how these arrangements are linked to objectives and performance measures, including any link to priorities on [economy / environment / people impacts, using your organisation’s own wording]; - the source documents or approvals that support the summary; - the period covered, scope, and any exclusions. A simple table is fine. Please use your internal terms first, then we will map them for the report. This is a possible LRA training template only; please adapt it to your organisation and check the official source before sign-off. Thanks, [preparer name]
Short Teams / Slack version
Hi [name/team] — could you share the pay policy summary for [board / senior leaders] for [period]? Please include base pay, variable pay, joining awards, exit terms, recovery clauses, pension, and how pay links to performance and impact priorities. A table plus source docs is perfect. Please use your internal terms first, then we’ll map them. This is a possible LRA training template only; please adapt it to your organisation and check the official source before sign-off.
Manufacturing
Context. A group with a board, plant leadership team and a formal annual bonus plan tied to safety, quality and delivery measures.
Adapted request. Please share the pay policy summary for the board and executive team for [period]. Include base pay, annual bonus, long-term awards, joining awards, exit terms, recovery clauses and pension arrangements, plus how the bonus and award outcomes link to safety, quality, delivery and wider impact priorities. Please attach the committee paper and policy version.
Example response. A table showing each pay element, who it applies to, the policy rule, the performance measures used, the approval date, and links to the committee paper and plan rules.
Financial services
Context. A firm with a remuneration committee, deferred incentives, malus/recovery terms and pension arrangements for directors and senior managers.
Adapted request. Please provide the current reward policy summary for directors and senior managers for [period]. Include fixed pay, annual and deferred incentives, joining awards, exit terms, recovery clauses and pension arrangements, and explain how outcomes are linked to business performance and impact priorities. Please include the committee-approved papers and the policy effective date.
Example response. A narrative summary plus a table listing each pay element, eligibility, performance conditions, deferral or recovery features, approval reference and source document.
The full request pack — response form, data table, evidence metadata and sign-off — is in the Download Centre.
LRA training templates — adapt them to your organisation, and check the official source before sign-off.
Explain which pay policies are covered, which leadership groups are included, and how each pay element has been defined for reporting purposes.
Set out what the disclosed pay arrangements indicate about how the organisation rewards leadership, including the balance between guaranteed and performance-linked elements and any special payments or safeguards.
If the policy changed during the period, note which pay elements were added, removed or revised, and explain any shift in the link between reward and performance expectations.
GRI 2-19 Remuneration policies — [location / page] / [notes]
Professional preparation tools and forms for GRI 2-19. Each download includes a concise “How to use” guide.
| Claim | Risk | Evidence to check |
|---|---|---|
| The information reported for this disclosure reconciles to the underlying source records. | What is reported cannot be traced back to the systems or documents it was drawn from, or does not tie out to them. | calculation_workbook reconciling the reported value to source_system_export |
| The information reported for this disclosure is current as at the reporting date. | The disclosure reflects a different period, a cut-off before the reporting date, or stale data carried over from a prior period. | approval_record showing the data cut-off date and the period covered |
| The scope behind the information reported for this disclosure is applied consistently. | Parts of the organisation are silently in or out of scope, or the scope differs from the prior period without that change being explained. | methodology defining the scope and a site_register of what it covers |
| Everything in scope is included in the information reported for this disclosure — nothing material is left out. | Parts of the population that should be reported are omitted, understating or overstating the disclosure. | site_register of the full population vs the calculation_workbook of what was actually included |
- The governing policy or written commitment behind this disclosure
- A methodology / definition note setting out how the disclosure was scoped and prepared
- Source-system exports the figures or facts were drawn from
- The internal approval / sign-off record for the disclosure before publication
- Minutes or records evidencing the relevant engagement or consultation
- The information is presented without a date or as-at point.
- The scope or boundary of the statement is left undefined.
- Key terms are used inconsistently across the report.
- Material changes since the previous period are not disclosed.
- Assertions are made without supporting detail or a source record.
- Boilerplate is used that does not actually answer what is asked.
- Wrong owner
The team asks HR alone and misses the board secretary, reward lead, or finance owner who actually holds the policy and approval trail.
- Framework language only
People ask for information using GRI-style labels instead of the organisation’s own pay terms, so the source team cannot map the request to the right documents.
- Scope not pinned down
The collector does not state which board members and senior leaders are in scope, so different teams send different populations and the draft becomes inconsistent.
- Wrong period basis
The data pull mixes the current policy position with changes made after the reporting cut-off, so the evidence no longer matches the period being described.
- Mixed counting basis
One source counts awards when granted while another counts them when paid, and the team combines them without aligning the basis first.
- Source labels stripped out
The original file names, table headings, and system tags are lost during copying, making it impossible to trace each figure back to its source.
- Populations merged
The collector combines board pay and senior management pay into one extract even though the organisation tracks them separately for approval and reporting.
- Evidence trail missing
The team saves the numbers but not the supporting emails, policy versions, or sign-off notes, so no one can show how the final data was agreed.
- Set the reporting boundary after a buy-in or sale
If a business has been bought or sold during the period, explain whether the pay policy narrative covers the full year, only the time the unit sat inside the group, or a restated view, and make the choice consistent with the rest of the report.
- Handle country-by-country pay terms with one common lens
Where local contracts use different labels or pay elements, map them to a single internal description and say how the local terms were grouped so readers can compare like with like.
- Decide how to treat people just inside or just outside the senior group
If someone moved into or out of the top leadership population near year-end, state the cut-off used and whether they are included because of role, pay setting, or time in post.
- Choose the timing basis for pay events
Be clear whether the narrative is built on awards granted, amounts earned, cash paid, or year-end entitlements, and explain that basis wherever it affects fixed pay, bonuses, exits, or retirement items.
- Separate estimates from confirmed amounts
When a pay element is not yet final, disclose that it is an estimate, say how it was derived, and update the figure later if the final amount differs materially.
- Explain any group-level rounding approach
If figures are rounded or banded for readability, state the method and make sure the rounded presentation still matches the underlying totals and sub-totals.
- Protect personal data when the leadership group is small
If naming or splitting out pay details could identify individuals, aggregate the information further and say that the presentation has been adjusted to avoid exposing personal data.
- Link pay design to performance using the organisation’s own measures
Where the pay policy is tied to objectives or results on economic, environmental, or social impact, explain which internal measures were used, how they were weighted, and whether the link is direct or only partial.
Synthetic, written by LRA — not from a company report, not text from any standard.
Synthetic illustration only. Our board and senior leaders are paid through a mix of base salary, annual bonus, long-term awards, and pension-style benefits; we also set out when any joining payment, exit payment, or repayment of awards can apply.
- Base pay is fixed in cash. For 2025, the board chair received £180,000 and the chief executive £420,000; the executive team totalled £1.26 million.
- Variable pay is linked to financial delivery and our economic, environmental, and social impact goals. In 2025, 62% of the annual bonus pool was earned and 48% of long-term awards vested.
- New-hire incentives, severance terms, and retirement benefits are described in our policy. No sign-on payment was made in 2025; one departing executive received £95,000 in contractual termination pay; and pension contributions were 12% of base pay for the board chair and 15% for the chief executive.
- Recovery clauses apply where results are later found to be misstated or conduct falls short of policy. During 2025, £210,000 of prior awards remained subject to possible recovery, and no amount was clawed back.
Synthetic illustration only. We pay directors and senior managers through a fixed salary, performance-related cash, share-based awards, and post-employment benefits, and we explain any recruitment, exit, or recovery terms in the same policy.
- Fixed cash pay is the core element: in 2025, the board chair received £150,000, the managing director £360,000, and the senior leadership group £980,000 in total.
- Variable pay depends on profit, safety, waste reduction, and community outcomes. For 2025, 71% of the annual incentive plan was paid out, and 55% of the deferred award tranche remained on track to vest.
- We did not pay any joining bonus in 2025. One leaver received £120,000 under an agreed exit arrangement, and retirement contributions were 10% of base pay for the chair and 14% for the managing director.
- If later checks show a material error or serious conduct issue, awards can be reduced or taken back. At year end, £180,000 of prior awards was still within the recovery window, and no clawback was triggered in 2025.
How to turn the collected data into a draft disclosure. Suggested visuals and a GRI content-index line generated from this disclosure's datapoints.
Suggested visuals
- Pay policy components by role group — stacked bar: How pay policy elements are described for the board-level group and for senior management, split into fixed pay, variable pay, joining incentives, exit-related payments, recovery provisions and retirement-related benefits.
- Link between pay design and performance focus — table: A side-by-side summary of how each pay element is set out and how it is connected to objectives and performance tied to the organisation’s economic, environmental and social impact.
- Remuneration mix across policy elements — bar: A comparison of the different pay-policy elements so readers can see which forms of reward are covered and where the policy emphasis sits.
- Governance pay safeguards overview — table: The main controls and conditions attached to executive and board pay, including any recovery arrangements, exit payments and recruitment-related incentives.
- Pay policy and performance linkage summary — table: How the organisation explains the relationship between reward arrangements and performance against its stated objectives, including impact-related objectives.
What separates a figure from a disclosure.
We paid our board and senior leaders fixed and variable pay, plus other awards, under our current pay policy.
We paid our board and senior leaders fixed pay, variable pay, joining awards, exit payments, clawback-linked amounts and retirement benefits, with variable pay tied to annual results and role-specific targets.
For the year ended 31 December 2025, we applied the same pay approach to our board and senior leaders across fixed pay, variable pay, joining awards, exit payments, clawback terms and retirement benefits, and we linked variable pay to financial, environmental and people-related goals because those measures drive how we manage our main impacts; the year-on-year rise in variable pay reflected stronger target delivery.
Real reports where this topic is disclosed. The confidence label shows how closely each match maps to GRI 2-19 — these are report practice, not exact disclosure examples.
| Company | Sector · Country | Year | Match | Page | Report | Assurance | |||||||||||||||||||||||||
|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|
| Interconexión Eléctrica S.A. E.S.P. | Electric Utilities / IPP / Energy Traders · Colombia | 2024 | Related | p. 139 →p. 138 →p. 29 → | ISA Integrated Management Report 2024 → | ey | |||||||||||||||||||||||||
Evidence in Interconexión Eléctrica S.A. E.S.P.’s reportWhat the report shows Interconexión Eléctrica S.A. E.S.P.'s 2024 Integrated Management Report does not provide any quotable evidence related to the disclosure in question, as no relevant narrative items were found in the report. There is also no clear information on the methodology or narrative for the disclosure, leaving the status of this data unclear. Overall, the report lacks coverage of the specified disclosure.
Evidence-based summary of this company’s own report — not a disclosure template to copy, and not a compliance verdict. Datapoint coverage
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| Indra Sistemas, S.A. | Software and Services · Spain | 2025 | Partial | p. 15 →p. 118 →p. 16 → | Sustainability Report 2025 → | — | |||||||||||||||||||||||||
Evidence in Indra Sistemas, S.A.’s reportWhat the report shows Indra Sistemas, S.A.'s Sustainability Report 2025 provides detailed information on its remuneration policy, stating that it is accessible to all stakeholders via the Intranet and outlines guiding principles for workforce compensation (p.116). The report specifies that fixed remuneration accounts for 25% and variable annual remuneration for 35% of total annualised pay (p.16). However, several narrative items related to remuneration disclosures are not found, and the methodology or further narrative explanation is unclear.
Evidence-based summary of this company’s own report — not a disclosure template to copy, and not a compliance verdict. Datapoint coverage
Source trail
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| TS Financial Holding Co., Ltd. | Banks / Diverse Financials / Insurance · Taiwan | 2024 | Exact | p. 47 →p. 171 →p. 32 → | 2024 CSR Report → | EY | |||||||||||||||||||||||||
Evidence in TS Financial Holding Co., Ltd.’s reportWhat the report shows TS Financial Holding Co., Ltd.'s 2024 CSR Report provides coverage on remuneration policies, including specific reference to the remuneration policy of senior executives on page 171 and details on remuneration, benefits, and employee care on page 24. The report also mentions related topics such as occupational health and safety and labor-management relations on page 126, and discusses remuneration policies by gender on page 134. However, several narrative items related to remuneration are not found or unclear, with no quotable evidence available for certain sub-items and methodology explanations.
Evidence-based summary of this company’s own report — not a disclosure template to copy, and not a compliance verdict. Datapoint coverage
Source trail
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The remuneration note has been drafted for the board pack, but it only says that directors receive a salary and an annual bonus. The people team also uses a one-off joining payment for a newly hired executive, and there is a pension arrangement for both directors and senior leaders.What extra policy areas should be described before this disclosure is ready for sign-off?
A draft says the bonus plan is linked to profit growth, but it does not explain whether the same approach applies to the board and the executive team, or whether any recovery clause exists if results were misstated later. The remuneration committee wants to keep the wording brief.How should the preparer decide whether the current draft is complete enough?
A company has a standard retirement package for senior leaders, but the board chair is on a separate arrangement with a higher employer contribution. The draft report mentions only the standard package because the team thinks the chair’s terms are too detailed for the main narrative.Should the report distinguish between different retirement arrangements for the board and senior executives?
The draft links annual bonus outcomes to financial targets only. The sustainability team says the board also has objectives tied to reducing workplace harm and improving environmental performance, but the remuneration section does not mention those links.What should the preparer explain about the connection between pay and performance?
See how companies actually report GRI 2-19 — drawn from their own published reports, with the exact pages, and an LRA AI-assistant that works through it with you. Available to LRA Community members and to students throughout their platform access.
How this disclosure maps across the major reporting frameworks.
GRI 2-19 General Disclosures: what should I gather before drafting the pay-related disclosure on this page?
Start with the datapoints listed on the page: base pay policy, incentive pay policy, joining bonus policy, exit payment policy, recovery policy, pension and retirement, and the pay-and-performance link. The page also gives a step-by-step preparation flow, so you can use it to organise the information before writing the draft. ↑ section
GRI 2-19 General Disclosures: how do I use the step-by-step 'how to prepare' section in practice?
Use it as a working sequence for collecting the required inputs, checking scope, and turning them into a draft disclosure. The page is designed to help you move from raw policy information to a report-ready narrative and supporting evidence. ↑ section
GRI 2-19 General Disclosures: which data owner should provide the base pay, bonus, pension and recovery policy information?
The page is set up for practitioner use, so the right owner is whoever holds the underlying policy or reward data in your organisation. In practice that is often HR, reward, payroll, or another internal data owner who can confirm the current policy position and evidence it. ↑ section
GRI 2-19 General Disclosures: what evidence should I keep to support the assurance claims on this page?
The page includes four assurance claims to verify and an evidence pack with five items to help you get assurance-ready. Use those sections together so you can link each claim to the supporting documents or records before the draft is finalised. ↑ section
GRI 2-19 General Disclosures: what are the common reporting gaps or mistakes I should check for before I submit?
The page lists common reporting gaps and mistakes, so it is meant to help you spot missing policy detail, weak support, or inconsistent drafting before submission. A good use is to compare your draft against that list and close any gaps with evidence from the workbook or source records. ↑ section
GRI 2-19 General Disclosures: how do I build an evidence pack for assurance readiness?
Use the page’s five-item evidence pack as the basis for your file set, then tie each item back to the relevant claim or datapoint. That gives you a cleaner audit trail and makes it easier for an assurance reviewer to follow the logic from source to disclosure. ↑ section
GRI 2-19 General Disclosures: can I use the synthetic illustrative example to draft my own disclosure?
Yes, the page includes synthetic illustrative example disclosures, including a quantitative table where relevant, to show how the information can be presented. Treat it as a formatting and drafting aid only, and replace the example figures and wording with your own organisation’s data and narrative. ↑ section
GRI 2-19 General Disclosures: how should I turn the data into a draft narrative and content-index line?
The page has a draft-output section with visualisation ideas, narrative starters, and a GRI content-index line. Use those prompts to convert the collected datapoints into a short, readable disclosure and a traceable index reference. ↑ section
GRI 2-19 General Disclosures: what should I download from the Download Centre and when should I use it?
The Download Centre provides a Prep & Assurance workbook in .xlsx format and a printable Library Card in .pdf format. Use the workbook to organise preparation and evidence, and the PDF if you want a quick reference copy for review or sign-off. ↑ section
GRI 2-19 General Disclosures: how do the 'from company reports' links help me prepare the disclosure?
The page includes a table linking to real published reports where the topic is disclosed, which can help you see how others have presented similar information. Use those links as practical reference points for structure and presentation, not as a substitute for your own organisation’s data and judgement. ↑ section
- GRI 2-19 General Disclosures workbook: how do I use the Prep & Assurance workbook to track datapoints, evidence and sign-off?
- GRI 2-19 General Disclosures evidence pack: what should be in the five-item evidence pack before assurance review?
- GRI 2-19 General Disclosures: how do I check whether my pay policy narrative covers base pay, incentive pay, joining bonus, exit payment, recovery policy, pension and performance link?
- GRI 2-19 General Disclosures: what are the most common mistakes when drafting the pay-related disclosure?
- GRI 2-19 General Disclosures: how do I write a short draft disclosure from the synthetic example and narrative starters?
- GRI 2-19 General Disclosures: who should own the data collection for pay policy, pension and performance-link information?
- GRI 2-19 General Disclosures: what should an assurance reviewer look for in the claim/risk/evidence section?
- GRI 2-19 General Disclosures: how do I use the printable Library Card alongside the workbook?
- GRI 2-19 General Disclosures: where can I find real company report examples for this topic on the page?
- GRI 2-19 General Disclosures: how do I avoid overclaiming if my organisation only has partial policy information?
- GRI 2-19 General Disclosures: what is the best way to turn the page’s datapoints into a report-ready table or narrative?
- GRI 2-19 General Disclosures: does the page give an exact ESRS, CSRD or ISSB mapping for this disclosure?
Get a practical answer for your reporting context. Your first answer is free — create a free account to continue the conversation.
Sources, status and disclaimer
This LRA assistance tool is designed for educational and internal data-collection purposes. It is not an official interpretation of the GRI Standards, IFRS Sustainability Disclosure Standards or EU CSRD/ESRS requirements. When applying these frameworks in professional practice, users should consult and double-check the official standards, guidance and applicable regulatory sources.