In determining which individuals to include in the disclosure tables for Key Management Personnel (KMP), Senior Executives and Other Highly Paid Staff (OHPS), consideration must be given to the type of employment arrangements in place.
Types of employment arrangements
Part time arrangements
KMP, senior executives and OHPS who work part-time and who meet the relevant inclusion criteria are to be included in the disclosures outlined in the PGPA Rule.
Changes to composition of KMP
During the reporting period the composition of the KMP may change due to:
- Machinery of Government changes which resulted in the transfer in or out of functions and the associated KMP,
- internal restructures such as the creation of a new business area due to a government policy, which resulted in an additional KMP, and
- rolling membership of an executive board, whereby independent members are replaced periodically.
In these situations, the total remuneration earned by the individual while a KMP during the reporting period is to be included in the relevant tables. It follows that any remuneration received while not a KMP should not be included.
Acting Arrangements – KMP
Entities need to exercise judgement in line with the definition of KMP in AASB 124 when determining whether persons acting as a KMP should be included in the KMP remuneration disclosures. The period of acting may not be a reliable indicator by itself and considerations should include:
- whether there is any acting arrangements directly preceding a permanent promotion to a KMP position, and/ or
- roles and responsibilities given to acting personnel (i.e. decisions made by, or involving, the person during the acting period and the significance of those decisions on the financial position, performance and operations of the Commonwealth entity), and/ or
- the length of time the individual spent in the acting arrangement during the reporting period.
Where persons acting are included in remuneration disclosures for KMP, the total remuneration paid to the individual while acting during the reporting period is to be included in the relevant tables. It follows that any remuneration paid while not acting should not be included.
Acting Arrangements – Senior Executives
As with acting KMP, entities should exercise judgement when determining what acting arrangements should be included in the disclosures for senior executive remuneration. The matters entities should consider are similar to those for acting KMP. Entities should use a footnote to explain the policy used to decide on when acting arrangements are to be included.
Where persons acting are included in senior executive disclosures, the total remuneration paid to the individual while acting during the reporting period is to be included in the relevant tables. It follows that any remuneration paid while not acting should not be included.
Promotion during the reporting period
Where an individual is promoted to a KMP position during the reporting period, all remuneration earned prior to the promotion is excluded from the KMP calculations for the purpose of this disclosure (unless included due to acting arrangements as above). The impact of the promotion on leave balances that existed prior to the promotion would also be excluded as they represent a movement in the provision arising from past service.
Where an individual is promoted to a senior executive position during the reporting period, remuneration earned prior to the promotion is excluded from the total remuneration calculations for the purpose of this disclosure. As with KMP, the impact of the promotion on leave balances would also be excluded from the remuneration disclosures.
There may be a situation whereby an individual’s remuneration details could be included in a number of the tables during the reporting period. For example, during the reporting period a senior executive may act in a KMP position for three months. The total remuneration for the three months would be included in the KMP table, while the remaining nine months of total remuneration would be included in the senior executive disclosure.
Transfers between Commonwealth entities
During the reporting period, individuals may transfer between Commonwealth entities. In these situations, the total remuneration earned by the individual in the entity they are attached to during the reporting period is to be included in the relevant tables. It follows that any remuneration earned while in the other entity should not be included.
In addition, assuming the leave balance moves with the individual when they transfer, it should be excluded from the executive remuneration disclosure as the leave balances have been previously recognised by the entity they transferred from.
Any adjustment to the leave balance that resulted from the transfer should be excluded in the executive remuneration disclosure, including any uplift in the provision due to changes in salary. For example, an individual transfer between entity A and B with an annual leave balance of $10,000 and due to salary adjustments relating to the transfer the annual leave balance increases by a further $500. This should be excluded from the executive remuneration disclosure. The long service leave provision movement (accrued long service leave less leave paid during the year) plus any changes in the transferee’s provision following the transfer in the reporting period should be included in the executive remuneration disclosure.
A secondment arrangement can be:
- in the case of an official of a Commonwealth entity, they formally remain an official of the home entity but are assigned duties in another Commonwealth entity, or with an outside employer (host employer), and
- if the employee is a non-Commonwealth entity employee, they are directed by their home employer to perform duties in a Commonwealth entity while continuing to be an employee of the home employer.
Typically, the home employer remains responsible for total remuneration and nearly all terms and conditions of engagement although the host employer may, for practical reasons, pay the person or reimburse the home Commonwealth entity for the costs of the secondee. For the purpose of the executive remuneration disclosure tables, these amounts are to be reported by the host employer. Where the home employer remains responsible for meeting a portion of the remuneration package of a secondee, the two entities involved in the secondment arrangement should agree on reporting arrangements to ensure there is no duplication of remuneration reporting.
For KMP, senior executives and other highly paid staff on secondment, total remuneration should reflect:
- where a formal written agreement for secondment exists, the amount of remuneration in accordance with the formal agreement, or
- where no formal written agreement for secondment exists, the remuneration details relating to the secondee should be obtained from the home Commonwealth entity.
In accordance with AASB 124 Related Party Disclosures, Commonwealth entities are not required to disclose a minister’s remuneration as this will be reported at the whole of government level in the Consolidated Financial Statements. Ministerial remuneration should therefore be excluded from the executive remuneration disclosures.