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There was no prior specific obligation on an AIM Company to explain the pay of Directors other than in its Admission Document. This means that if a Company did not volunteer the  information on interim appointments being made, shareholders would not know the specific terms of a particular director’s pay unless they served a requisition on the Company under s     Companies Act 2006.  Although a Company cannot impose a  condition of confidentiality as a term for release of such information, neither can it be presumed that a requisitionist is unfettered in how they publicise the information.
 
The AIM Rules now provide that for AIM companies with a financial year end of 31 March 2010 or thereafter , disclosure must be made in its audited accounts of:

• any transaction with a related party, whether or not previously disclosed under the AIM Rules, where any of the class tests exceed 0.25% and must specify the identity of the related party and the consideration for the transaction; and
• details of directors’ remuneration earned in respect of the financial year by each director of the AIM company acting in such capacity during the financial year.
 
Directors’ remuneration means :
a) emoluments and compensation, including any cash or non-cash benefits received;
b) share options and other long term incentive plan details, including information on all outstanding
options and/or awards; and
c) value of any contributions paid by the AIM company to a pension scheme.

The AIM Rules still do not compel companies to disclose  Directors’ remuneration  when they fill a casual vacancy outside of the audited account reporting regime. This point came under particular scrutiny by shareholders who requisitioned a General Meeting of Lupus Capital plc in October 2009.

Following  that company’s refinancing in April 2009, the Executive Chairman Greg Hutchings left and two new interim directors were appointed as CEO and CFO. There was no  public disclosure at the time of their appointment  of the pay of the new interim directors.  Subsequent requisitions by shareholders revealed that the new Directors were  paid on a daily rate with milestone related success payments which annualised at some £1.5 million between them.  In the space of some 9 months, Lupus Capital plc has seen a turnover of 11 Directors on its Board with 5 Board departures and 6 appointments.  Lupus perhaps learned the lesson of earlier controversies when announcing the appointment  in 2010 of its new CEO with effect from February 2010 . In that case they set out his  salary remuneration package.