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Demystifying the Remuneration Report:
Turning Compliance into Communication 


By Ziankha Amorette


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The Financial Reporting Council’s (FRC) new guidance on Non-Executive Director (NED) remuneration, published as part of the UK Corporate Governance Code updates, sets out clearer expectations for how boards approach and explain pay. While it doesn’t change the Code itself, the update clarifies how the “comply or explain” principle gives companies flexibility in structuring NED remuneration in a way that suits their business. Boards can, for instance, now pay part of NED fees in shares to encourage long-term alignment with shareholders, as long as they’re transparent about the rationale behind that approach. 

Crucially, the guidance also reinforces an important boundary: while NEDs may hold shares, independent NEDs must not receive performance-related pay such as share options. Their independence is what allows them to bring objective challenge and expertise, free from the influence of day-to-day management or short-term targets. This clarification is a timely reminder that effective governance reporting is about transparency and balance: demonstrating how companies align interests, preserve independence, and communicate those decisions openly to stakeholders. 


That balance extends to the wider Remuneration Report itself, which demonstrates how fairly and transparently a company communicates its approach to reward. At Black Sun Global, our research shows that clarity and storytelling can transform what’s often viewed as regulatory exercise into something readers genuinely understand and trust. 


Companies are increasingly linking remuneration to their broader strategic ambitions. According to our Complete 100: Trust in Transition research, most companies now include non-financial requirements in remuneration policies - seven in ten companies linked sustainability to bonuses, and six in ten to LTIP (long-term incentive plan) arrangements. When companies take that extra step, they turn compliance into communication. To move your remuneration report away from being a box-ticking exercise and towards integrating it into your purpose narrative, we recommend: 

  • Linking pay to purpose - Use clear scorecards or visuals to show how remuneration is linked to company purpose, strategic goals, and sustainability priorities

  • Include "Remuneration at a Glance" - Have a one page spread upfront to summarise key outcomes, metrics, and year-on-year changes 

  • Show alignment with wider workforce remuneration trends and policies - Demonstrate how the company considers employees when making executive pay decisions 

  • Provide robust explanation for Committee discretion - When discretion is exercised, clearly set out the rationale, circumstances considered, and any shareholder consultation to demonstrate independent judgement  

  • Disclose findings from shareholder and workforce consultations - Explain how input from these groups has shaped remuneration policies and adjustments


At Black Sun, we see great remuneration reporting as an opportunity to build trust, not just meet requirements. With insights from our Complete 100: Trust in Transition research and decades of experience in corporate and climate reporting, we help companies turn complexity into clarity and connect pay to purpose. Get in touch to explore how we can help you bring your reporting to life.


About Black Sun

Black Sun Global is a stakeholder advisory and engagement agency that's been driving transformation and positive change for ambitious brands for more than 20 years. With deep expertise in disclosure and reporting, ESG, sustainability, and digital engagement, we reshape how organisations connect with customers, investors, employees, and the wider world. 

We are trusted partners to some of the most influential global organisations, sparking innovation and sustainable performance through our strategic insights, partnerships, and proprietary technologies.

As founders of the Positive Change Group, we are on a mission to create a new kind of stakeholder relations partner. Our world-class specialists work closely with executive leadership teams to protect reputations, inspire trust, and promote responsible business practices - building resilience and long-term value in a rapidly changing world.

For more information, please visit: www.blacksun-global.com




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