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GRI Training Partner GRI 2 · General Disclosures · Disclosure GRI 2-19

Remuneration policies

GRI 2-19 · mandatory · narrative disclosure

Disclosure 2-19 requires an organization to describe the remuneration policies applicable to members of its highest governance body and senior executives. The disclosure is focused on the content of the policies and does not require the organization to report individual remuneration amounts or actual incentive outcomes.

Disclosure focus

The highest governance body is the governance body with the highest authority in the organization. The term “Board” should be used only where the Board is the organization’s highest governance body. A senior executive is a high-ranking member of management, such as the Chief Executive Officer or an individual reporting directly to the CEO or the highest governance body.

The organization must describe the remuneration policies for both populations, including:

1. fixed pay and variable pay;2. sign-on bonuses or recruitment incentive payments;3. termination payments;4. clawbacks;5. retirement benefits.

Fixed and variable pay can include performance-based remuneration, equity-based remuneration, bonuses, deferred shares and vested shares. Where performance-based pay is used, the organization should explain how remuneration for senior executives is designed to reward long-term performance.

Sign-on bonuses and recruitment incentive payments should be distinguished from ordinary annual or long-term variable remuneration. If the organization does not provide recruitment incentives, it should state this directly.

Termination payments include all payments and benefits provided when the appointment of a highest governance body member or senior executive is terminated. They can include non-cash benefits and automatic or accelerated vesting of incentives. Where termination payments are provided, the organization should explain relevant notice periods, differences from the arrangements for other employees, payments beyond the notice period and any mitigation clauses.

Clawbacks are repayments of compensation already received. They should be distinguished from malus, forfeiture, downward adjustment or cancellation of remuneration that has not yet been received or vested.

For retirement benefits, the organization should explain the differences between the retirement benefit schemes and contribution rates applicable to members of the highest governance body, senior executives and all other employees.

The organization must also describe how the remuneration policies for members of the highest governance body and senior executives relate to their objectives and performance in managing the organization’s impacts on the economy, environment, and people. Where no such relationship exists, the organization should state this directly rather than creating or implying an impact-related incentive.

The content of the remuneration policies is reported under Disclosure 2-19. The process for designing the policies and determining remuneration, including the role of independent governance members, stakeholder views and remuneration consultants, is reported separately under Disclosure 2-20. Annual compensation ratios are reported under Disclosure 2-21.

Actual remuneration amounts, incentive payouts, vesting outcomes, individual termination payments and amounts clawed back are optional additional information and are not mandatory datapoints under Disclosure 2-19.

If a specified remuneration policy or arrangement does not exist, the organization should report this fact directly. Reasons for omission are permitted for Disclosure 2-19 where required information cannot be reported. In that case, the organization must identify the affected requirement and provide an applicable reason for omission and the required explanation in its GRI content index.

This LRA educational guidance supports disclosure preparation. For the exact requirements, always refer to the official GRI source.

Prepare

What to collect before drafting

Tick each field as the evidence lands. Owners are the teams that usually hold the source files.

  • Fixed and variable pay policies

    People / Remuneration / Finance

    Describe fixed and variable pay policies for members of the highest governance body and senior executives.

    Evidence Dated source records, governance papers and approval evidence supporting fixed and variable pay policies.

    Watch for The published response for fixed and variable pay policies is incomplete or does not match the supporting records.

  • Recruitment incentives

    People / Remuneration / Finance

    Describe sign-on bonuses or recruitment incentive payments, or state that none are provided.

    Evidence Dated source records, governance papers and approval evidence supporting recruitment incentives.

    Watch for The published response for recruitment incentives is incomplete or does not match the supporting records.

  • Termination payments

    People / Remuneration / Finance

    Describe termination-payment policy, including relevant non-cash benefits and accelerated vesting.

    Evidence Dated source records, governance papers and approval evidence supporting termination payments.

    Watch for The published response for termination payments is incomplete or does not match the supporting records.

  • Clawbacks

    People / Remuneration / Finance

    Describe policy requiring repayment of compensation already received, or state that no clawback applies.

    Evidence Dated source records, governance papers and approval evidence supporting clawbacks.

    Watch for The published response for clawbacks is incomplete or does not match the supporting records.

  • Retirement benefits

    People / Remuneration / Finance

    Describe policies and differences in schemes and contribution rates between required populations.

    Evidence Dated source records, governance papers and approval evidence supporting retirement benefits.

    Watch for The published response for retirement benefits is incomplete or does not match the supporting records.

  • Link to impact-management objectives and performance

    People / Remuneration / Finance

    Explain how policies relate to objectives and performance in managing impacts, or state that no relationship exists.

    Evidence Dated source records, governance papers and approval evidence supporting link to impact-management objectives and performance.

    Watch for The published response for link to impact-management objectives and performance is incomplete or does not match the supporting records.

Before you start

  • Cover members of the highest governance body and senior executives; do not expand the mandatory population to the whole business.
  • Describe policies, not individual amounts or actual outcomes, and keep policy content separate from the GRI 2-20 process.
  • Have the supporting records and the final response been reconciled?
+ Show GRI 2-19 sub-elements (LRA working checklist)

How to prepare it

Cover members of the highest governance body and senior executives; do not expand the mandatory population to the whole business.
Collect and reconcile the records for: Fixed and variable pay policies; Recruitment incentives; Termination payments; Clawbacks; Retirement benefits; Link to impact-management objectives and performance.
Describe policies, not individual amounts or actual outcomes, and keep policy content separate from the GRI 2-20 process.
Draft the response using the defined terms shown in the disclosure focus; do not substitute broader internal labels.
Review the final wording against every requirement and the supporting governance or data records before sign-off.

Request the data

Request the disclosure evidence

Translate the disclosure into an internal business question — then adapt it to your organisation's own language.

Provide approved remuneration policies for the required populations, covering each specified policy element and the relationship to impact-management objectives and performance.

Use the organisation's own role and document names, but preserve the defined GRI terms and the scope described above.

Better request

Provide approved remuneration policies for the required populations, covering each specified policy element and the relationship to impact-management objectives and performance.

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

Distinguish clawbacks from malus, forfeiture or cancellation of remuneration not yet received or vested.

Context note

State explicitly where a policy element or impact-related link does not exist; actual amounts and outcomes are optional context.

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Preparation tools & forms

Download preparation tools for GRI 2-19 with free verified email access for 24 hours. Source-report links remain public.

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Check

For each claim, check the evidence

  • Fixed and variable pay policies is reported accurately and completely.

    Risk The response omits, misclassifies or overstates fixed and variable pay policies.

    Evidence to check Dated source records, governance papers and approval evidence supporting fixed and variable pay policies.

  • Recruitment incentives is reported accurately and completely.

    Risk The response omits, misclassifies or overstates recruitment incentives.

    Evidence to check Dated source records, governance papers and approval evidence supporting recruitment incentives.

  • Termination payments is reported accurately and completely.

    Risk The response omits, misclassifies or overstates termination payments.

    Evidence to check Dated source records, governance papers and approval evidence supporting termination payments.

  • Clawbacks is reported accurately and completely.

    Risk The response omits, misclassifies or overstates clawbacks.

    Evidence to check Dated source records, governance papers and approval evidence supporting clawbacks.

  • Retirement benefits is reported accurately and completely.

    Risk The response omits, misclassifies or overstates retirement benefits.

    Evidence to check Dated source records, governance papers and approval evidence supporting retirement benefits.

  • Link to impact-management objectives and performance is reported accurately and completely.

    Risk The response omits, misclassifies or overstates link to impact-management objectives and performance.

    Evidence to check Dated source records, governance papers and approval evidence supporting link to impact-management objectives and performance.

Evidence pack to prepare

Common reporting gaps

  • Applying the disclosure to pay across the whole business.
  • Replacing senior executives with senior leaders or managers.
  • Mixing policy content with the remuneration-determination process.
  • Treating every recovery mechanism as a clawback.
  • Implying impact-linked incentives exist where the policy has no such relationship.
✓ Knowledge Hub AI Assistant · Human-in-the-loop
Dr Ross Kurinko

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Framework references

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