A FTSE SMALL CAP Group Counsel & Company Secretary writes...
Companies and LLPs of a certain size will soon need to report on a half-yearly basis on their payment practices, policies and performance. This applies for financial years beginning on or after 6 April 2017. The information must be published through an online service provided by the government, and will be available to the public. As regards your company/LLP who (or which department/function) has primary responsibility for meeting these requirements? Is it regarded as a “finance” responsibility or a “legal/compliance” one? And if your company/LLP has an audit committee, will responsibility for oversight of these requirements come within that committee’s remit?
For us it was legal who identified the requirement around 12M ago, put a paper together for the Board on ambit of disclosure, timelines and grey areas (we appended some of the government guidance to paper) and then worked with finance over the year who put together the numbers.
The Audit Committee reviewed the draft disclosure and approved it on behalf of the Board.
We also had some useful consultancy from KPMG, on how other companies had approached some of the more tricky aspects.
This is seen as a finance responsibility of our UK operating companies but with other functions eg legal and Company Secretariat involvement. It is not being put to the Audit Committee.
Payment practices reporting falls within the remit of the finance department. There are two key operating subsididiaries which we are required to report on. The operating boards for these entities (which are mostly made up of individuals from the UK&I Exec team) have oversight of the reports and approved them during one of the board meetings.