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.
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Fixed and variable pay policies
People / Remuneration / FinanceDescribe 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.
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Recruitment incentives
People / Remuneration / FinanceDescribe 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.
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Termination payments
People / Remuneration / FinanceDescribe 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.
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Clawbacks
People / Remuneration / FinanceDescribe 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.
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Retirement benefits
People / Remuneration / FinanceDescribe 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.
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Link to impact-management objectives and performance
People / Remuneration / FinanceExplain 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?
How to prepare it
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.
Download Centre
Preparation tools & forms
Download preparation tools for GRI 2-19 with free verified email access for 24 hours. Source-report links remain public.
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.
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Advice, not assurance
Framework references
Relevant GRI requirements and related disclosures
GRI
GRI 2-19
within GRI 2: General Disclosures
Guides that settle this question
Related & explore
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