do I need to share remuneration policy for board members in esg questionnaire

Usually not mandatory, but increasingly often requested

No, executive compensation policy is not a mandatory answer in most ESG questionnaires, but it is appearing increasingly often as a separate question alongside questions about management composition. Under the VSME baseline module of EFRAG, the standard that most customers use as a format for their SME suppliers, compensation policy is not part of the baseline indicators. It therefore usually does not fall within the core of what a customer asks to comply with the CSRD obligation.

However, you do encounter the question, especially with customers who go beyond the minimum or who are themselves listed on a stock exchange and translate stricter own standards down their supply chain. If you do not have a documented compensation policy, then "not applicable" or "no separate policy" is an honest answer — you do not need to invent something that does not exist. If you do have arrangements regarding executive compensation, for example documented in a shareholders' agreement or articles of association, then that is the source from which the answer comes. This question is often linked to the question who sits on the board and how it is composed; customers who ask about compensation usually also ask about composition.

Where this does not follow from a legal obligation

Executive compensation policy is not in the baseline module of EFRAG VSME (efrag.org) and does not follow from the Wwft either, which only addresses customer due diligence and says nothing about executive compensation. Directive 2022/2464 (CSRD) requires reporting on certain governance indicators for the reporting undertaking itself, but does not stipulate that the undertaking must request the compensation policy of each supplier. If a customer asks for it anyway, that is their own addition beyond the standard format — similar to how customers sometimes also ask further questions on describe the whistleblowing procedure while that question likewise is not in every baseline list.