customer asks about our remuneration policy for management members, do I need to fill that in

Remuneration policy for management: part of board governance, not a privacy question

Yes, this is a question you can usually answer, but not with payslips or individual amounts. The question falls under the governance and management section of a sustainability questionnaire, usually in the same group as questions about board composition and independence of board members. What is typically asked is whether there is a policy exists — so a document with principles — and sometimes whether variable remuneration is linked to sustainability objectives. The latter is a specific EFRAG VSME point and differs from the simple yes/no question about the existence of a policy.

Distinguish two levels. Level 1: does the enterprise have an established remuneration policy for management/board (fixed salary, variable component, severance as categories, not as amount)? This can usually be answered with yes once there is an internal document or statutory regulation, even if it has been formally recorded informally in a management regulations document or shareholder resolution. Level 2: is variable remuneration linked to ESG criteria (for example CO2 reduction, safety figures)? That is a no if that link does not exist — a plausible answer for many SMEs, and no problem, because the standard asks for it without it being mandatory. Individual remuneration of board members does not belong here; if a client asks for it anyway, that is a moment to look at the confidentiality button before you share anything. This question often comes together with questions about who is on the board, so it is worth making both answers consistent at the same time.

Basis in the VSME governance module

The EFRAG VSME standard addresses board remuneration policy in the basic module under the governance and management indicators, as a supplement to the core questions about board composition. The standard distinguishes between the existence of a policy and the link to sustainability performance; so you ask those two separately. This is separate from the Anti-Money Laundering Directive, which concerns customer due diligence and is not relevant here, and separate from CSRD obligations that only apply to larger enterprises — for SMEs this remains voluntary, which explains why formats differ from customer to customer.