Disclosure focus
This disclosure asks an organisation to explain how it decides pay and other remuneration for its governing body and senior executives. In practice, the focus is on the process: who is involved, what information is considered, and how decisions are made and approved. The organisation should make clear whether the approach is formal and consistent, or more ad hoc, and whether it applies across the whole organisation rather than only to a few high-profile roles or sites.
The practical point is to show that remuneration is determined through a defined process that can be understood by readers. That usually means describing the main steps, the roles of committees or decision-makers, and any factors used to assess pay. The report should help users see how remuneration is set in practice, not just state that it exists.
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 2-20 sub-elements (LRA working checklist)
Set out how pay policies are designed and how pay levels are decided, including how stakeholder views — such as those of shareholders — are gathered and used.
Explain whether the board’s independent members, or a separate independent pay committee, oversees the pay-setting process.
State whether outside pay advisers help decide remuneration, and if they do, whether they are independent from the organisation, the board and senior leaders.
If votes have been held on pay policies or pay proposals, report the voting outcome.
How to prepare it
1Set the reporting boundary first: confirm which entity, period and decision-making bodies are in scope for this disclosure, so you are clear whose pay-setting process you are describing.
2Map the pay-setting process in plain language: explain how the organisation designs pay policy and how actual pay decisions are made, then note whether the board’s independent members or a separate pay committee has oversight.
3Gather the stakeholder input trail: collect records showing how views on pay were requested, from whom they were sought, and how those views fed into the final approach, including shareholder input where relevant.
4Check any external advisers used: confirm whether pay consultants helped with pay decisions, and if so, document whether they were independent from the organisation, the board and senior management.
5Compile the voting outcome, if there was one: prepare the results of any stakeholder or shareholder vote on pay policy or pay proposals, and make clear whether a vote actually took place.
6Review the final disclosure against the source material: make sure the narrative or figures match the underlying records, and note any exclusions, changes or limits in what is being reported before sign-off.
Request the data
Request the remuneration process evidence
Translate the disclosure into an internal business question — then adapt it to your organisation's own language.
How do we explain how pay decisions are designed, reviewed and approved, and what evidence do we have for any stakeholder voting outcomes?
Use your organisation’s own terms first, then map them to the reporting disclosure. For example, speak about pay policy, bonus design, board approval, committee review, shareholder engagement and vote outcomes in the language your teams already use. This is a possible LRA training template; adapt it to your organisation and check the source material before sign-off.
Weak request
Please provide the GRI 2-20 evidence for remuneration governance, including the process, stakeholder input, consultant independence and voting results.
Why it fails: It uses framework language that many internal teams will not recognise, and it bundles several different evidence needs into one vague ask. That makes it harder for the owner to know which papers, trackers or approvals to pull together, and it does not point them to the internal records they actually hold.
Better request
Please send the papers and records that show how pay policy and pay decisions were shaped and approved for [period], including the board or committee route, any employee or investor feedback that was considered, any outside adviser used and their relationship to the company, and any vote results on pay policy or pay proposals. If you have a governance tracker, board paper pack or AGM result file, that is ideal.
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 the basis used to describe how pay policy is set, who is involved in the decision-making, how stakeholder views are gathered and reflected, and whether any external pay adviser is separate from the organisation and its senior leadership.
Context note
Set out what the figures and descriptions show about the organisation’s approach to pay governance, including the level of oversight, the role of stakeholder input, and the outcome of any shareholder or stakeholder votes.
Fluctuation statement
If the approach changed during the period, note whether this was due to a change in oversight arrangements, consultation practice, adviser independence, or the results of votes on pay-related proposals.
Content index entry
GRI 2-20 Process to determine remuneration — [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 request goes to HR or payroll alone, even though the information sits with the board secretary, the pay committee, investor relations, or the team that runs the pay policy process.
Framework language only
The data call asks for GRI-style labels instead of the organisation’s own terms, so teams cannot map the request to how they actually run pay decisions.
No boundary set
The collector does not say which entity, board level, or pay cycle is in scope, so responses mix group and subsidiary information without a clear cut-off.
Wrong period basis
The team pulls the latest policy wording or a current-year snapshot when the disclosure needs the period actually covered by the report, so the evidence and narrative do not align.
Mixed counting basis
Votes, committee members, and consultant checks are gathered using different population rules, which makes the figures and yes/no answers impossible to compare cleanly.
Source labels lost
The original file names, meeting references, and vote descriptions are stripped out during consolidation, so the reviewer cannot trace each point back to its source.
Populations merged
Independent directors, committee members, and other decision-makers are rolled into one list even though they should be kept separate for the process description.
Evidence metadata missing
The pack arrives without dates, version numbers, or document owners, so no one can tell which draft, meeting pack, or vote record was used.
No sign-off trail
The draft is assembled from emails and spreadsheets without a clear review or approval record, so there is no audit trail showing who checked the final data set.
Where judgement is often needed
Who actually steers pay design
If the board, a committee beneath it, or another internal group shares the work, spell out which group leads the design and pay-setting process and how that split is handled in your narrative.
Outside advisers with mixed independence
Where a pay adviser works across the business, the board, or senior leaders, explain the basis for treating them as independent or not, and note any safeguards or limits you rely on.
Different country pay rules in one group
If local entities use different pay practices or legal terms, describe the group-wide approach you use to explain the process and flag any country-level differences that affect how remuneration is set.
People near the reporting boundary
Be clear whether you include or leave out joint ventures, newly acquired units, sold businesses, or other edge-of-scope teams, and explain the cut-off you used so readers can see why the population changed.
Stakeholder input that is indirect or partial
If views on pay come through surveys, investor meetings, employee forums, or representative bodies rather than direct consultation, explain how you gathered them and how much weight they had in the final decision.
Votes that are advisory, split, or not comparable
When reporting voting outcomes on pay policies or proposals, state the voting basis, the period covered, and how you handled abstentions, split classes, or different voting rights so the result is not misleading.
Using estimates versus measured figures
If some parts of the process are based on judgement, sampling, or estimates rather than direct records, say where that happened, why it was needed, and whether later actual data changed the story.
Rounding and presentation choices
If you round vote totals, percentages, or counts of advisers and governance participants, use one consistent method, make sure the rounded figures still add up sensibly, and explain the basis if it affects interpretation.
Protecting personal data in small populations
Where the number of people involved is so small that naming them could identify individuals, aggregate the information before disclosure and explain the level of grouping you used.
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.* We set pay through a board-led annual review, with an independent pay committee making the detailed recommendation and the full board approving the final package. In shaping the policy, we gather investor feedback through the AGM season, direct meetings and a short annual survey; we also use an external pay adviser who is independent of us, the board and senior management. - At the latest vote, 92% of shares cast supported the pay policy (460,000,000 for; 40,000,000 against; 0 abstentions), and 89% supported the annual pay award for directors (445,000,000 for; 55,000,000 against; 0 abstentions).
This synthetic disclosure shows how a reporter can explain who oversees pay, how outside views are gathered, whether an external adviser is used and independent, and how shareholder voting outcomes are reported.
Illustrative (synthetic) example — food manufacturing
*Synthetic illustration only.* Our remuneration approach is drafted by management, reviewed by the remuneration committee and then signed off by the board; the committee is made up entirely of non-executive directors. We seek stakeholder views through investor roadshows, written consultation and feedback from employee representatives, and those views are considered before any changes are finalised. - An external consultant supports benchmarking and plan design; the firm is independent of our group, the board and executive leaders. - In the most recent vote, 78% of votes cast backed the policy (312,000,000 for; 88,000,000 against; 0 abstentions) and 81% backed the implementation report (324,000,000 for; 76,000,000 against; 0 abstentions).
This synthetic disclosure demonstrates a second plausible reporting style, with a different sector, different governance setup, a different route for stakeholder input and a separate voting result.
Company reports
How companies report GRI 2-20
Real reports where this topic is disclosed. These are report practice, not exact disclosure templates to copy.
Port of Melbourne
Water Transportation — Ports and Services · Australia · 2025
Port of Melbourne’s 2025 Sustainability Report includes coverage of narrative item (a-i) with reference to GRI 1 Foundation 2021 and GRI 2: General Disclosures 2-1 on page 62, indicating some standard disclosures are reported. The report also addresses narrative item (b) on page 67, detailing policies and practices related to the collection, usage, and retention of customer information. However, narrative items (a-ii) and (a-iii) lack clear or quotable evidence in the report, leaving those aspects unclear.
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 provides information on the independence of its Board of Directors, stating that the members do not belong to the organization (p.134). The report also outlines various policies related to employees, communities, shareholders, and other stakeholders, including occupational safety and health (p.59). However, there is no clear or quotable evidence regarding the methodology or narrative for certain narrative items (a-ii and a-iii), which remain unspecified.
Chang Hwa Commercial Bank, Ltd.
Banks / Diverse Financials / Insurance · Taiwan · 2024
Chang Hwa Commercial Bank's 2024 ESG Report provides information on the process to determine remuneration and annual total compensation ratio (p.198), as well as details on remuneration policies and procedures (p.48). The report also references performance evaluation of the Board of Directors, including senior executives such as the President and Executive Vice Presidents (p.33). However, there is no clear evidence regarding the methodology or narrative for certain aspects of the disclosure (a-ii), which remains unaddressed in the report.
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Check your understanding
Scenarios to work through
A listed group has a board pay committee that drafts executive pay policy, while the full board signs off on the final package. The reporting team is unsure whether to mention the committee’s role, the board’s role, or both.
QWhat should be explained about how pay decisions are shaped and who oversees that work?
Reveal model answer →Hide answer ↑Set out the practical steps used to design pay policy and decide pay, and make clear whether the work is overseen by independent board members or by an independent pay committee. If both the committee and the board play a part, describe each role in plain language.
Why this matters · Readers should be able to see who shapes pay and whether independent oversight is in place.
During the year, the company held meetings with major investors and also received written comments from employee representatives on bonus design. The draft report mentions only the investor meetings because they were easier to summarise.
QHow should the organisation handle outside views on pay when writing this disclosure?
Reveal model answer →Hide answer ↑Include the ways outside views on pay were gathered and explain how those views were taken into account, not just that contact happened. If shareholders and other stakeholder groups both contributed, describe the main channels and how the feedback influenced the process.
Why this matters · The disclosure should show both how views were sought and how they affected the pay-setting process.
A remuneration adviser helped benchmark executive packages and draft the policy. The adviser also provides tax planning services to the chief executive, and the reporting team is unsure whether that connection matters.
QWhat needs to be clarified about any external pay adviser involved in the process?
Reveal model answer →Hide answer ↑State whether an outside pay adviser was used, and if so, explain whether that adviser was separate from the organisation, the board, and senior management. If the adviser had other ties that could affect independence, those ties should be made clear in the explanation.
Why this matters · Where an external adviser is involved, the report should make its independence, or lack of it, transparent.
At the annual meeting, shareholders voted on the pay policy and on the bonus plan. The company has the vote totals, but the draft report only says the vote took place and does not show the outcome.
QWhat should be reported about stakeholder voting on pay matters?
Reveal model answer →Hide answer ↑If a vote on pay policy or a pay proposal took place, report the result of that vote. The disclosure should not stop at saying a vote happened; it should show the outcome in a way that is clear to readers.
Why this matters · When a vote on pay is relevant, the outcome belongs in the disclosure, not just the fact of the vote.
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
For GRI 2-20, what data do I need to collect before I start drafting the disclosure?+−
The page says to prepare four datapoints: the pay design process, stakeholder pay input, external pay advisers, and the pay vote outcome. Use those as your starting checklist before you draft anything.
How do I use the step-by-step 'how to prepare' section for GRI 2-20 in practice?+−
Use it as a working sequence for gathering the disclosure inputs, checking what evidence exists, and turning that into a draft. The page is designed to help you move from source data to a report-ready narrative.
Who should own the GRI 2-20 data collection in my organisation?+−
The page is aimed at sustainability/ESG managers, HR or data owners, and assurance reviewers, so ownership should sit with the people who can source and explain the pay-design and voting information. The page does not assign a single owner, so you need to set that internally.
What evidence should I keep for GRI 2-20 so I am assurance-ready?+−
The page includes an evidence pack with five items and four assurance claims to verify, each with a claim, risk and evidence angle. Use those materials to build a file that shows where the data came from and how it was checked.
What are the four assurance claims to verify for GRI 2-20?+−
The page says there are four assurance claims to verify, but the exact claims are part of the page content rather than a separate rule set. In practice, use the claim/risk/evidence prompts in the assurance section to test whether your disclosure is supported.
What are the most common mistakes people make when reporting GRI 2-20?+−
The page lists common reporting gaps and mistakes to help you avoid weak or incomplete disclosures. Use that section as a pre-submission check so you do not miss the required datapoints or supporting evidence.
Can I use the synthetic example disclosure on the GRI 2-20 page as a template for my draft?+−
Yes, as a drafting aid only. The page includes synthetic illustrative examples, including a quantitative table, so you can see how the disclosure might be presented without treating it as a real company example.
How do I turn my GRI 2-20 data into a draft narrative and table?+−
The page has a draft-output section with visualisation ideas, narrative starters and a GRI content-index line. Use those to convert your collected data into a clear first draft and then tailor it to your own reporting style.
What should go into the GRI 2-20 evidence pack for assurance review?+−
The page provides an evidence pack with five items to support assurance readiness. Use it to assemble the documents and records that back up the pay-design process, stakeholder input, adviser involvement and vote outcome.
Where can I download the GRI 2-20 workbook and library card?+−
The Download Centre includes a Prep & Assurance workbook in .xlsx format and a printable Library Card in .pdf format. These are there to help you organise the disclosure work and keep a quick reference copy to hand.
More questions this page can help with
GRI 2-20 pay design process: what should I collect before drafting?GRI 2-20 stakeholder pay input: what evidence should I look for?GRI 2-20 external pay advisers: how do I document them in the disclosure?GRI 2-20 pay vote outcome: how should I capture the result for reporting?How do I use the GRI 2-20 Prep & Assurance workbook?What is in the GRI 2-20 printable Library Card PDF?What are the GRI 2-20 common reporting gaps I should check before sign-off?How do I build an assurance evidence pack for GRI 2-20?What does the GRI 2-20 plain-language explainer cover?Are there synthetic example disclosures for GRI 2-20 I can use to shape my draft?Does the GRI 2-20 page provide a GRI content-index line for the draft output?Are there real company report examples linked from the GRI 2-20 page?
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