Monday, 22 November 2010

What Walker said last year

The blurb below is from the original July 2009 Walker Review consultation document. Notice that he explicitly acknowledges that 'going it alone' on remuneration disclosure has drawbacks, but he concludes that other concerns - shareholder oversight and public interest - outweigh this. What has changed then to justify a change of policy? Is it just 'business as usual'?
It is then for consideration whether new disclosure provisions should be put in place to cover remuneration in this “high end” category to provide an indication of numbers of executives within it, with detail in specified compensation bands. Possible reasons for reservation about this include the fact that principal shareholder focus is most likely to relate to how interests are best aligned through appropriate incentive structures than to absolute levels of remuneration. There would also be some risk that the signalling influence of such further disclosure could exacerbate upward pressure on remuneration through intensifying the competitive process, in line with the view that disclosure of board level remuneration has probably exerted upward ratcheting influence of this kind.

There can be no question of turning the clock back in this respect, but great care will be needed to assess the likely, in some degree predictable though obviously unintended, consequences of further disclosure in this area. In any event, in this as in other related matters (such as the later discussion in this chapter on the gap between the highest and lowest-paid employees) there would be a proper concern to avoid tilting the playing field against UK-listed entities through requiring a degree of further disclosure going beyond what is likely to be required in their principal competitors.

There is, however, precedent in the US, Australia, Hong Kong and elsewhere for disclosure of the remuneration of a specified number of the most highly remunerated at the top of the “high end” category. And given the recent experience in which
inappropriate remuneration structures contributed to the severity of the crisis phase, there would seem to be legitimate shareholder and wider public interest in disclosure in relation to this “high end” category of executives which have large business and risk-related responsibilities. In this situation, and despite the reservations described above, it would seem justified to seek appropriate but anonymous disclosure of the total remuneration cost for all in this category.

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