do I need to fill in management remuneration policy in customer questionnaire

Remuneration policy for management is usually not a mandatory answer for SMEs

No, in most cases a non-listed company does not need to share the remuneration policy of management. The basic module of the VSME standard of EFRAG, which was created for non-listed SME companies, asks about the number of employees, working conditions in outline and gender data about the board — not about remuneration structures or salaries of individual board members. If the question does appear literally in your client's list, this is almost always because the client uses its own, more comprehensive questionnaire that goes beyond the standard, not because the standard requires this.

If you are unsure whether the question about remuneration is actually a question about board composition in disguise, first look at how the question about the composition of the board of directors is usually asked — these two are often asked in one breath, but are very different in terms of burden of proof. If you do not have a documented remuneration policy, then "no, no policy" in the basic module is a valid answer; there is no obligation to draw one up for this questionnaire.

What this is based on: the VSME basic module and the CSRD

The VSME basic module of EFRAG is the guideline here, because it was specifically drawn up for the target group that receives questionnaires from larger clients without themselves falling under the CSRD (Directive 2022/2464). The CSRD itself only obliges detailed governance and remuneration reporting to large, reporting-obligated undertakings — the client sending out the list falls under it, the supplier usually does not. If the client does ask for remuneration policy, check whether this is separate from the standard questions about integrity and conflicts of interest, such as the procedure for conflicts of interest — remuneration and conflicts of interest are quite often put in the same paragraph of a questionnaire in practice, but are two separate subjects each with their own evidence.