Process to determine remuneration
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 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.
A quick mental checklist before you prepare this disclosure — tick each as you settle it.
| Datapoint | What to capture | Evidence hint | Owner |
|---|---|---|---|
| Pay design process | A plain description of how pay policies are set and how individual pay decisions are made, including whether the board’s independent members or a separate pay committee oversees the decision process. | Remuneration policy papers, committee terms of reference, board minutes, approval papers, and governance charts showing who reviews and signs off pay decisions. | Reward / HR with Company Secretariat and Board Committee support |
| Stakeholder pay input | How the organisation asks for and uses views on pay from stakeholders, including shareholders, when shaping pay policy and pay decisions. | AGM engagement notes, investor feedback logs, consultation summaries, board papers, and records showing how comments were considered. | Investor Relations with Reward / HR and Company Secretariat |
| External pay advisers | Whether outside advisers help with pay setting, and if they do, whether they are separate from the company, the board, and senior management. | Adviser engagement letters, conflict checks, independence declarations, committee papers, and procurement records for pay advisers. | Reward / HR with Procurement and Company Secretariat |
| Pay vote outcome | The voting result from stakeholders, including shareholders, on pay policy or pay proposals, where a vote took place. | AGM voting results, proxy adviser reports, meeting minutes, and the final tally for each relevant pay resolution. | Company Secretariat with Investor Relations |
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.
LRA working checklist - paraphrased; see official source
- Set 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.
- Map 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.
- Gather 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.
- Check 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.
- Compile 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.
- Review 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.
Translate the disclosure into an internal business question — then adapt it to your organisation's own language.
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.
Please provide the GRI 2-20 evidence for remuneration governance, including the process, stakeholder input, consultant independence and voting results.
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.
Formal email template
Subject: Request for pay process evidence for [reporting period] Hi [name/team], We are preparing the sustainability/governance reporting pack and need the evidence behind how pay decisions were designed and approved for [reporting period]. Please share, or point us to, the materials that show: - who reviewed and approved the pay approach; - how stakeholder views were gathered and considered; - whether any outside adviser supported the process, and if so, their relationship to the company and senior leaders; - any vote results on pay policy or pay proposals, where relevant. Please include the source document, date, owner, and any notes needed to interpret the material. If it is easier, you can return the information in the table below and attach the supporting papers. Thanks, [Your name] [Team] [Contact details]
Short Teams / Slack version
Hi [name] — could you send over the pay process evidence for [period]? We need the board/committee papers, stakeholder feedback route, any adviser details, and any vote results on pay policy/proposals. Please include the source docs and dates. Thanks.
Listed financial services
Context. The company has a remuneration committee, uses an external pay adviser, and holds an annual shareholder vote on the pay report and policy.
Adapted request. Please share the remuneration committee papers, adviser engagement note, and AGM vote result file for [period]. We need the board route, how investor feedback was considered, whether the adviser was independent from the company and senior management, and the final vote counts on the pay policy and pay report.
Example response. Committee minutes, adviser appointment note, independence confirmation, investor engagement log, AGM results spreadsheet with votes for/against/withheld, and the final board-approved pay report draft.
Manufacturing
Context. The business does not have a separate remuneration committee, but the board reviews senior pay and the company secretary keeps the AGM voting record.
Adapted request. Please send the board paper and approval note for senior pay decisions in [period], plus any employee or shareholder feedback that was considered and the AGM vote summary on the pay resolution. If an external adviser helped shape the pay approach, please include their engagement note and any independence check.
Example response. Board paper on annual pay review, approval minute extract, employee forum summary, proxy voting report, and adviser engagement memo confirming scope and relationship status.
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 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.
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.
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.
GRI 2-20 Process to determine remuneration — [location / page] / [notes]
Professional preparation tools and forms for GRI 2-20. 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 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.
- 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.
Synthetic, written by LRA — not from a company report, not text from any standard.
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).
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).
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
- How pay decisions are governed — table: A side-by-side summary of who oversees pay-setting, whether an outside adviser is used, and whether that adviser is separate from the company and senior leaders.
- Inputs used in setting remuneration — stacked bar: A breakdown of the main influences on pay design, including board oversight, committee involvement, stakeholder input, and external adviser support where relevant.
- Stakeholder views on pay — bar: A comparison of the different stakeholder groups consulted on remuneration and how their views were taken into account in the process.
- Voting outcomes on pay matters — bar: The results of votes on pay policies or proposals, showing support and opposition where votes were held.
- Use of independent advisers — donut: The share of remuneration decisions supported by independent advisers versus other arrangements, where the organisation uses consultants.
What separates a figure from a disclosure.
I say our pay-setting process is overseen by the board and a committee, and the latest vote on pay was 92% in favour.
I say the board and its pay committee shape our reward approach, we gather shareholder and other stakeholder views before decisions, and the latest vote on our pay policy passed with 92% support.
I say the board and pay committee review our reward design each year, we also seek and weigh shareholder and wider stakeholder views, we use an external adviser that is independent of us, the board and senior leaders, and the latest vote on pay policy and proposals was 92% in favour because investors supported the clearer link to performance.
Real reports where this topic is disclosed. The confidence label shows how closely each match maps to GRI 2-20 — these are report practice, not exact disclosure examples.
| Company | Sector · Country | Year | Match | Page | Report | Assurance | ||||||||||||||||
|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|
| Port of Melbourne | Water Transportation — Ports and Services · Australia | 2025 | Exact | p. 62 →p. 25 →p. 34 → | Port of Melbourne 2025 Sustainability Report → | EY | ||||||||||||||||
Evidence in Port of Melbourne’s reportWhat the report shows 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.
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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| Interconexión Eléctrica S.A. E.S.P. | Electric Utilities / IPP / Energy Traders · Colombia | 2024 | Partial | 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 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.
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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| Chang Hwa Commercial Bank, Ltd. | Banks / Diverse Financials / Insurance · Taiwan | 2024 | Partial | p. 33 →p. 198 →p. 48 → | 2024 ESG Report → | PwC | ||||||||||||||||
Evidence in Chang Hwa Commercial Bank, Ltd.’s reportWhat the report shows 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.
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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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.What should be explained about how pay decisions are shaped and who oversees that work?
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.How should the organisation handle outside views on pay when writing this disclosure?
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.What needs to be clarified about any external pay adviser involved in the process?
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.What should be reported about stakeholder voting on pay matters?
See how companies actually report GRI 2-20 — 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.
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. ↑ section
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. ↑ section
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. ↑ section
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. ↑ section
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. ↑ section
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. ↑ section
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. ↑ section
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. ↑ section
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. ↑ section
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. ↑ section
- 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?
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.