do I need to make the remuneration policy of management transparent for the questionnaire

Remuneration policy of management: question belongs to governance pillar, not to privacy or AML

The question about transparency regarding the remuneration policy of the management usually appears in the governance section of a sustainability questionnaire, separate from questions about integrity and whistleblowers. It concerns whether it is documented how the remuneration of executives is structured — fixed salary, variable component, any link to sustainability objectives — and whether that policy is documented somewhere and, in some questionnaires, also published. The latter word "transparent" is interpreted differently by clients: sometimes they mean internally documented, sometimes externally accessible. Without clarification from the client, you cannot fill in that difference with certainty.

If you do not have a separate, documented remuneration policy — which is normal for a large part of the SME population — then "no" is the factually correct answer, not a disguised "yes, informally yes". If the remuneration of the management is discussed in another document, for example the annual report or a shareholders' agreement, that can serve as evidence as soon as you are sure it covers the question. This question often appears in the same question set as the question about the composition of the management, and clients who pay attention to governance also often ask about is a policy against bribery and corruption — three questions that together provide a picture of how the management is structured and controlled.

Basis: VSME basic module, no statutory obligation for SMEs

This question comes from the governance indicators of the VSME basic module of EFRAG, the voluntary reporting standard for non-listed undertakings. It is not an obligation that directly results from the CSRD (Directive 2022/2464) on SME undertakings — that directive imposes reporting obligations on large and listed companies, and those companies then pass that obligation through in their own supply chain questionnaires. For SMEs, completing it is therefore voluntary, unless a specific client makes it a contractual condition.