Disclosure focus
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.
Before you start
A quick mental checklist before you prepare this disclosure — tick each as you settle it.
Preparation
Key datapoints to prepare
＋ 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.
How to prepare it
1Set 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.
2List 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.
3Gather 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.
4Draft 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.
5Record 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.
6Check 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.
Request the data
Request executive pay policy details and supporting evidence
Translate the disclosure into an internal business question — then adapt it to your organisation's own language.
How are pay arrangements for directors and senior leaders set, and how do they link to performance and impact priorities?
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.
Weak request
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.
Why it fails: It uses framework language that many internal owners will not recognise, and it bundles the ask in a way that is hard to action. It also risks prompting a narrative answer without the source documents, scope, and approval details needed to verify the summary.
Better request
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.
Industry examples
Draft your disclosure
Notes that turn data into a disclosure
LRA training templates — adapt them to your organisation, and check the official source before sign-off.
Method note
Explain which pay policies are covered, which leadership groups are included, and how each pay element has been defined for reporting purposes.
Context note
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.
Fluctuation statement
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.
Content index entry
GRI 2-19 Remuneration policies — [location / page] / [notes]
Download Centre
Preparation tools & forms
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Assurance readiness
For each claim, check the evidence
Evidence pack to prepare
Common reporting gaps
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.
Common gaps
Mistakes to avoid when collecting the data
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.
Where judgement is often needed
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.
Examples
Illustrative examples
Synthetic, written by LRA — not from a company report, not text from any standard.
Illustrative (synthetic) example — Renewable energy
*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.
This example shows how to explain pay design for the board and senior management in plain language, while linking incentives to performance on the organisation’s wider impacts.
Illustrative (synthetic) example — Food manufacturing
*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.
This example demonstrates a second sector-specific way to describe the same disclosure, with different figures and a different mix of performance measures.
Company reports
How companies report GRI 2-19
Real reports where this topic is disclosed. These are report practice, not exact disclosure templates to copy.
Interconexión Eléctrica S.A. E.S.P.
Electric Utilities / IPP / Energy Traders · Colombia · 2024
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.
Indra Sistemas, S.A.
Software and Services · Spain · 2025
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.
TS Financial Holding Co., Ltd.
Banks / Diverse Financials / Insurance · Taiwan · 2024
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.
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Check your understanding
Scenarios to work through
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.
QWhat extra policy areas should be described before this disclosure is ready for sign-off?
Reveal model answer →Hide answer ↑The write-up should cover the main pay elements for the board and senior leaders, not just salary and bonus. It should also explain any joining payment used to attract someone in, any end-of-service payment terms, any recovery provisions, and any retirement-related benefits, so the reader can see the full pay approach.
Why this matters · Cover each pay element that sits within the policy, not only the obvious cash components.
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.
QHow should the preparer decide whether the current draft is complete enough?
Reveal model answer →Hide answer ↑The disclosure should make clear how the pay approach applies to both the top governing group and senior managers, and it should include whether variable pay can be adjusted or taken back later. If the draft leaves out the recovery feature, it is not yet giving the full picture of the policy.
Why this matters · Explain the policy in a way that lets readers understand how incentives can move up, down, or be recovered.
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.
QShould the report distinguish between different retirement arrangements for the board and senior executives?
Reveal model answer →Hide answer ↑Yes. If the board and senior leaders are covered by different retirement terms, the disclosure should reflect that the policy is not identical across the group. The point is to describe the actual approach in place, including any separate retirement benefit terms that apply to those covered by the disclosure.
Why this matters · Do not flatten different pay terms into one generic description if the policy differs in practice.
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.
QWhat should the preparer explain about the connection between pay and performance?
Reveal model answer →Hide answer ↑The disclosure should show how pay policy connects with the objectives and results of the board and senior leaders when they are managing the organisation’s effects on the economy, environment, and people. If some incentives depend only on financial targets, that should be clear; if other objectives are also used, those links should be described too.
Why this matters · Show how incentives relate to both business results and the organisation’s wider impacts.
Framework references
Related framework references
How this disclosure maps across the major reporting frameworks.
Primary
Related & explore
Organizational details → Guide ✓Nomination and selection of the highest governance body → Guide ✓Chair of the highest governance body → Guide ✓Role of the highest governance body in overseeing the management of impacts → Guide ✓Delegation of responsibility for managing impacts → Guide ✓Role of the highest governance body in sustainability reporting → Guide ✓Show all 29 related disclosures →
FAQ
Questions this page answers
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
More questions this page can help with
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?
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