13.1.1 Disclosure is the publication in the Remuneration Report of the salary, bonus, pension and compensation details of your senior management, and of summary data on your use of exit packages. The Remuneration Report should also include details of your remuneration policy and the nature of contracts of those covered by the Report. Further information about the preparation of Remuneration Reports is contained in Section 5 of the Financial Reporting Manual (FReM).
13.1.2 The senior management team will normally be your Management Board or a similar group of very senior officials. You should find out who is included because each department or agency or Non Departmental Public Body is responsible for deciding which posts are covered by the disclosure requirements. The notice in Annex 13D must be sent to all staff covered by the disclosure requirements.
13.1.3 You must disclose salary and pension information on all departmental ministers and members of the senior management team. You must also disclose any compensation payments paid to members of the senior management team on loss of office, although you must tell them in advance of your intention to disclose, invite them to see what you intend to publish, and tell them that they can object under Article 21 of the General Data Protection Regulation (GDPR). Ministers are paid severance payments under statute. You do not disclose compensation paid to Ministers.
Non-disclosure is possible unless you can demonstrate, under the GDPR, compelling legitimate grounds for the disclosure which override the interests, rights and freedoms of the member or for the establishment, exercise or defence of legal claims. If a member does not agree to disclosure, you must consider whether to accept it. You are strongly advised to take legal advice in such a case, because if you decide not to publish this may be challenged under the Freedom of Information Act. Where non-disclosure is agreed, the fact that certain disclosure has been omitted should be disclosed.
13.1.4 You should disclose the following information in a Remuneration Report:
13.1.5 The use of exit packages for all staff should be reported in a note to the resource accounts. An example of the requirement is included in Annex C. Form of disclosure sources of information
13.1.6 We have included an example of a Remuneration Report at Annex 13C. Where an individual has a non-standard pension arrangement (e.g. accelerated accrual or membership of the Supplementary Scheme), you should disclose this in the report.
13.1.7 You should obtain information on salary, bonuses, benefits in kind, and exit packages from your records.
13.1.8 You should approach RPMI for pension information relating to Ministers using Annex 13B.
13.1.9 You should send the Annex 13A to MyCSP for pension information for civil servants.
Your pensions administrator will not be able to start calculating the disclosure figures until after the pension system has been updated after the March 2021 payroll. The figures for anyone who started working for you late in the reporting year may be delayed while your pensions administrator obtains the relevant data.
13.1.10 If you have any civil servants who are members of the Civil Service Supplementary (Earnings Cap) scheme, you should advise MyCSP who will combine Supplementary Scheme figures with the main scheme figures.
13.1.11 When you are preparing your Remuneration Report, you may find that you have individuals covered by the report who were appointed during the reporting year.
You may also have individuals who left during the reporting year. You should disclose the date of appointment, or last day of service as appropriate.
It is essential that the Remuneration Report includes the details of any individual that has retired during the financial year.
13.1.12 You should only disclose the pay, benefits in kind and pension information that relate to the period during which they were in a post subject to disclosure. However, you should also disclose the full year equivalent of the salary. The following example illustrates this point:
A civil servant joins the Board of the department on 1 July 2021. Between 1 July 2021 and 31 March 2022, they received a salary of £90,000. You should disclose the salary of £90,000 in the Remuneration Report, that this was only for nine months, and that the full year equivalent is £120,000. You should not disclose the salary they received before 1 July 2021.
You should still disclose the CETV for 31 March 2022, which is the end of the reporting period. However, you should disclose the CETV at 30 June 2021 (which is the value immediately before the individual joins the Board) rather than 31 March 2021.
If the civil servant was subject to disclosure in their previous post then the opening figure in your accounts should match the closing figure in their previous employer’s accounts.
If an individual is new to the Civil Service you will not have a figure for the start date.
13.1.13 If a member of the senior management team has opted to have a partnership pension account rather than joining the pension scheme then you should disclose this in the Remuneration Report.
13.1.14 You should ask your payroll provider to work out the total employer contributions paid to the partnership pension provider in the reporting year. You should disclose this figure in the Remuneration Report to the nearest £100.
13.1.15 You should include a note in your departmental resource accounts that contains:
13.1.16 We suggest that you base this note on the following example:
‘The Principal Civil Service Pension Scheme (PCSPS) and the Civil Servant and Other Pension Scheme (CSOPS) – known as “alpha” – are unfunded multi-employer defined benefit schemes but (insert employer’s name) is unable to identify its share of the underlying assets and liabilities.
The scheme actuary valued the PCSPS as at 31 March 2016. You can find details in the resource accounts of the Cabinet Office: Civil Superannuation.
For 2021-22, employers’ contributions of £XXXX were payable to the PCSPS (2020-21 £XXXX) at one of four rates in the range 26.6% to 30.3% of pensionable earnings, based on salary bands.
The Scheme Actuary reviews employer contributions usually every four years following a full scheme valuation. The contribution rates are set to meet the cost of the benefits accruing during 2021-22 to be paid when the member retires and not the benefits paid during this period to existing pensioners.
Employees can opt to open a partnership pension account, a stakeholder pension with an employer contribution. Employers’ contributions of £XXXX were paid to one or more of the panel of three appointed stakeholder pension providers. Employer contributions are age-related and ranged from 8% to 14.75%.
Employers also match employee contributions up to 3% of pensionable earnings. In addition, employer contributions of £XXXX, 0.5% of pensionable pay, were payable to the PCSPS to cover the cost of the future provision of lump sum benefits on death in service or ill health retirement of these employees.
Contributions due to the partnership pension providers at the balance sheet date were £XXXX. Contributions prepaid at that date were £XXXX.
13.1.17 You should disclose details of the number and total additional accrued pension liabilities, payable by the PCSPS/alpha for individuals who retired early on health grounds during the year, in the notes to the departmental resource accounts.
13.1.18 You do not need to report a capitalised figure for the additional accrued pension liabilities. You should request from your pensions administrator, and report, the difference between the pension the member received after retiring on ill-health grounds and the pension they would have received had they resigned on that date.
Your note would then read:
‘XXX individuals retired early on ill-health grounds; the total additional accrued pension liabilities in the year amounted to XXX.’