Chapter 2
Termination Payments
What problem is the bill trying to fix?
2.1
The principal justification provided for the bill is mounting community
concern. The Minister stated in his second reading speech:
There is significant community concern about the levels of
termination benefits paid to company management. Such payments are given to
outgoing company directors and executives at a time when they are no longer
able to influence the company’s future performance. The government’s reforms
will empower shareholders to more easily reject such payments where they are
not in the best interests of the company, the shareholders or the community.[1]
2.2
In announcing the measure on 18 March 2009, the Treasurer referred to
community concern about 'obscene' and 'outrageous' termination payments, and
the need to 'ensure that executive pay is in step with good corporate
governance, provides the correct incentives and meets decent community
standards'.[2]
The Explanatory Memorandum also refers to community concern as motivation for
the bill.[3]
Trends in executive remuneration
2.3
Executive remuneration as a whole is a matter beyond the scope of this
inquiry. However, the committee received evidence that the topic of termination
payments cannot be seen in isolation from the wider context of executive
remuneration. Concern about the level of overall executive salaries also helps
to explain community concern about the level of termination payments.
2.4
The committee received evidence that there has been a significant
increase in executive salaries in recent years. Professor David Peetz of
Griffith University provided evidence that:
The
growth in CEO pay, of something around 470 per cent over the period 1971‑2008,
was nearly nine times the 54 per cent growth in real average weekly earnings over
the same period.[4]
2.5
Mr Gary Banks, Chairman of the Productivity Commission, which is
currently undertaking an inquiry into executive remuneration, has noted:
...it
is hardly a revelation to say that both executive and (non-executive) director
remuneration have been increasing relatively rapidly — at least until last year
— albeit with executive pay at much higher levels and increasing at a faster
rate than for directors.[5]
2.6
Mr Banks noted that there is a lack of data, particularly in relation to
non‑executive directors. He also stated that media reports sometimes
exaggerate the extent of executive salaries due to the complexity of incentive
packages and other factors.[6]
2.7
An alternative view of executive remuneration was provided by the
Australian Chamber of Commerce and Industry. They argued that that claims that
executive remuneration are significantly higher than other sectors of the
economy are sometimes overstated:
...it must also be recalled that
there are other professionals, for example, in our sports, entertainment,
business, medical and legal industry, that are remunerated above and beyond
most average Australian incomes and corporate executives. These professions are
not subject to detailed regulatory interventions or restrictions in terms of
total remuneration packages or termination payments. Such persons would earn
many times over that of an average Chief Executive Officer or senior executive
in most Australian firms, and without any clear measurable benchmark to overall
performance or result.[7]
2.8
Other submissions referred to executive remuneration as unbalanced:
Also in need of correction
are the imbalances between those rewards and the rewards given to other
employees of the same corporations, and the rewards for work given to workers
in society generally. These imbalances must be corrected if social equity and a
reduction in inequality are to remain goals of Australian society, and goals of
the Government of that society.[8]
Are termination payments
'excessive?'
2.9
Discussion of termination payments often refers to certain high profile
cases.[9]
2.10
In announcing the government's decision, the then Minister for Financial
Services, Senator the Hon Nick Sherry, referred to payouts provided to Mr Owen
Heggarty of Oz Minerals (who in 2008 'received a bonus of $8.35 million, which
was 642 per cent of his base salary') and Mr John Anderson of Consolidated
Media who in 2008 'received a $15 million golden parachute, 468 per cent of his
salary'.[10]
2.11
Regnan's submission provides some further examples. These include
Mr Kim Edwards of Transurban Group, who received $16 million remuneration
in his final year, including a termination payment of $5.2 million. After his
retirement on 4 April 2008, the share price at Transurban fell from $6.60 to
$3.91 on 12 March 2009.[11]
2.12
Professor David Peetz provided examples in his submission of media
reports of large individual payments. These include among others a '$16 million
golden handshake' provided to Mr John Ellice-Flint (Santos)[12]
and a 'farewell package' of $32 million provided to Mr Chris Cuffe
(Colonial First State).[13]
2.13
One topical example at the time of the bill was announced was that of Mr
Sol Trujillo of Telstra. Media reports suggest that Mr Trujillo 'would get $3
million termination payments on top of his base salary of more than
$13 million'.[14]
Telstra has pointed out that Mr Trujillo's payment would be within the new
standards.[15]
Are 'excessive' payments standard
practice?
2.14
It is not clear the extent to which these individual examples are
representative of standard practice among companies.
2.15
In 2004, an article in the Australian Financial Review found:
An analysis...of the latest annual reports released by 50 of
Australia's largest companies reveals that nearly a third of chief executives
are entitled to termination payments worth more than the equivalent of 12
months salary, as well as performance-linked bonuses and entitlements to shares
and options. Eight CEOs are entitled to payouts of at least $4 million if their
employment is terminated, while some agreements have controversial provisions
that trigger big payouts to the CEO if control of the company changes.[16]
2.16
In 2005, Geof Stapledon estimated that in Australia termination payments
range from $800,000 to $9.9 million. The mean payment was $3.65 million and the
median was $3 million.[17]
2.17
In 2007, Kym Sheehan and Colin Fenwick of the University of Melbourne
examined termination provisions in executive service contracts:
Given a hypothetical termination date of 1 March 2006, nine
of the 28 companies examined would have paid an amount equivalent to at least
18 months' cash remuneration by way of contractual termination payment to the
managing director.[18]
2.18
All these figures predate the Global Financial Crisis.
2.19
Some submissions argued the upward trend in termination benefits has
stalled. According to the Hay Group, 'there has been a progressive downward
trend towards contracted termination payments of between 10 and 15 months fixed
annual reward over the last five years'.[19]
2.20
Table 1 provides an indication of the size of current termination provisions
in the ASX20 companies in Australia.
2.21
Treasury cited RiskMetrics data (released November 2008) which indicates
that the average CEO receives just over $3.4 million as a termination payment,
or 201 per cent of their salary, based on entities in the S&P/ASX 100
in the previous three years. Based on these data, Treasury found that 20 of the
33 CEOs included in the sample (around 60%) would exceed the proposed new
threshold, with the rate expected to decline for smaller companies. They
conclude:
Based on this research, it would appear that between
approximately 50 to 60 per cent of termination benefits would be captured by
[the 12 month] threshold, which Treasury considers to be an appropriate level.[20]
Table 1: Termination Pay Arrangements in the ASX20
Company
|
Less
than 12 month base
|
Summary
of Termination arrangements for key management personnel
|
AMP Ltd
|
No
|
12
months' fixed pay. Executives retain unvested equity incentives subject to
performance hurdles.
|
ANZ
Banking Group
|
No
|
CEO is
entitled to greater of the remainder of employment contract or 12 months'
fixed.
|
BHP
Billiton Ltd
|
Yes
|
12
months' base pay.
|
Brambles
Industries Ltd
|
Yes
|
12
months' fixed pay.
|
Commonwealth
Bank of Aust.
|
Yes
|
6
months' notice for CEO. Other executives between 6 and 12 months base.
|
CSL Ltd
|
No
|
12
months' fixed pay plus 6 months notice.
|
Foster's
Group Ltd
|
Yes
|
12
months' fixed pay.
|
Macquarie
Group Ltd
|
Yes
|
4
weeks' notice plus profit share already accrued.
|
National
Australia Bank Ltd
|
Yes
|
12
months' fixed pay for CEO, similar for other Key Management Personnel.
|
Newcrest
Mining Ltd
|
Yes
|
12
months' fixed pay.
|
Origin
Energy Ltd
|
Yes*
|
Senior
executives three months' payment in lieu of notice plus a severance payment
based on length of service, to a maximum of 74 weeks. Managing director 12
months' fixed pay if terminated for poor performance.
|
QBE
Insurance Group Ltd
|
Yes
|
12
months' fixed pay.
|
Rio
Tinto Ltd
|
No
|
12
months' fixed pay plus pro rata STI. Unvested LTIs retained and subject to
hurdles
|
Suncorp-Metway
Ltd
|
Yes*
|
12
months' fixed pay for CEO and most key management personnel. Some former
Promina executives entitled to up to 18 months fixed pay.
|
Telstra
Corp Ltd
|
Yes*
|
CEO and
COO 12 months' base pay. Some key management personnel are entitled to 18
months' base pay.
|
Wesfarmers
Ltd
|
No
|
Two
years' base pay.
|
Westfield
Group
|
Discretionary*
|
Termination
payments are discretionary.
|
Westpac
Banking Corp
|
Yes*
|
12
months' fixed remuneration for most executives. 12 months' fixed pay for CEO
if terminated for poor performance otherwise sign on shares may be awarded if
terminated prior to December 2009.
|
Woodside
Petroleum Ltd
|
Yes
|
12
months' fixed remuneration.
|
Woolworths
Ltd
|
No
|
12
months' fixed remuneration plus pro-rated STI.
|
* As a general standard.
Some exceptions may apply.
Source: Australian Council of Super Investors (document
tabled at public hearing, 25 August 2009).
Are claims of 'excessive'
termination payments exaggerated?
2.22
The Australian Institute of Company Directors (AICD) pointed out that
publicity given to individual payments made to individuals often overstates the
size of termination payments:
Another source of difficulty has been that the nature of
payments made at the end of employment is often misunderstood by members of the
public. Such payments can consist of a number of components such as unpaid
leave, long service leave, superannuation and other ordinary contractual
entitlements. To this a sum is often added to compensate for loss of office,
either pursuant to a pre-agreed contractual arrangement or a negotiated
settlement in lieu of damages for breach of contract. To the public eye the
aggregate sum may seem excessive whereas only the latter elements can be
influenced by the board.[21]
2.23
The Business Council of Australia (BCA) and ACCI presented similar
arguments.[22]
Geof Stapledon also noted this phenomenon in his 2005 study.[23]
2.24
Ernst & Young referred to the lack of clarity surrounding the
disclosure of remuneration arising from complex accounting rules:
The disclosed remuneration for an individual does not
therefore relate to the cash value received by the executive. This
disconnect results in frequent misinterpretation by shareholders, media and the
public, resulting in the sometimes false perception that an executive is
overpaid. Similarly, an executive may receive significant remuneration value
that is not immediately apparent from the disclosure.[24]
Risk and tenure
2.25
Several submissions from industry provided arguments that high
termination payments represent compensation to executives for the risky nature
of such positions.
2.26
The AICD point out that 'the average term of office for a CEO in
Australia is now less than five years. CEOs are therefore keen to ensure that
they are financially protected in the event that their term of office is
shorter than anticipated'.[25]
2.27
The BCA put the average tenure of an executive at 5.7 years.[26]
The BCA also pointed out high turnover of CEOs, noting that CEO turnover was 18
per cent in 2007, an increase of 60 per cent since 2000, and the highest level
in the world.[27]
2.28
The AICD gave a further illustration of risks faced by directors:
There
are 267, we think, state laws making directors liable. One of the biggest
problems in this country at the moment, we would argue, is that, under federal
laws for example, you have laws which reverse the onus of proof, which say, ‘You are guilty until you have proved yourself innocent.’ That transgresses
fundamental laws like the Magna Carta. It transgresses fundamental laws like
the bill of rights...And you have a system now where there are class actions
against directors. You have a system now where there is a massive amount of
federal and state laws making directors liable. Is this a big issue? Yes. What
happens when liability goes up and risk goes up? Price goes up. So there is
definitely a very high coefficient between risk and reward...[28]
2.29
Professor Peetz argued in his submission that other employees in the
economy also face risk:
If there is increasing risk facing
CEOs, it is no greater than the increased risk facing ordinary employees
compared to two decades ago, as they work in what is sometimes referred to as the
'risk society'...The increased casualisation of employment has transferred many
of the risks of employment from capital onto labour...
The argument about greater risk
faced by CEOs is especially difficult to sustain when we compare the
termination packages to which that CEOs typically have access with those
available to ordinary workers...The substantial safety nets in event of dismissal
provided by the 'golden parachutes' of CEOs are much more generous than those
available to ordinary workers.[29]
2.30
The Australian Council of Super Investors (ACSI) submission also noted
that such payments 'exceed anything available to the rest of the workforce'.[30]
2.31
ACCI argued that 'restraint of trade' clauses in executive contracts may
prevent executives from seeking employment with a competitor for a reasonable
period of time. 'Because of the lengthier and more excessive restrictions on an
executive than other employees, the quid pro quo is often a higher than
average premium to the executive'.[31]
The Law Council of Australia also noted the impact of restraint of trade
clauses.[32]
Consequences of 'excessive'
termination payments
2.32
Some submissions and commentators have argued that excessive termination
benefits have an impact on the wider economy, justifying government
intervention.
2.33
A frequently stated view is that termination payments constitute a
'reward for failure'. Treasury cited this perception in its submission:
A service contract may provide that no termination benefit is
payable in cases where the executive is dismissed for cause, for example, in
the event of misconduct. However, this has not prevented the payment of
termination benefits where the executive's performance has been below the
expected standard, but not to the extent that it would constitute 'cause.' This
has reinforced the perception that termination benefits are a reward for poor
performance.[33]
2.34
ACSI also noted that 'excessive termination payments appear to not only
reward executive directors for mediocre performance, but in some cases, for
failure'.[34]
2.35
Some submissions argued that excessive payments promote risk-taking
behaviour by executives. The argument appears to be that an executive may be
willing to endorse a high risk in order to obtain high returns, in the
knowledge that he or she will receive vast bonuses if the 'gamble' comes off
and at worst still get millions in the event that the 'gamble' fails. This
could lead to CEOs having a perverse incentive to undertake a risky project
with a negative expected return, against the interests of shareholders and the
broader community.
2.36
The Australian Manufacturing Workers' Union (AMWU) argued:
It is becoming increasingly apparent that highly leveraged
short term incentives for executives and directors inappropriately promote: a
short‑term focus, excessive risk-taking and highly individualistic
behaviour.[35]
2.37
This does not take into consideration other impacts on executives who
might be removed for poor performance, for example damage to reputation:
There is a risk reputationally. I don’t think there is any
question that, in our experience, a person who strives for a senior executive
position or a board position is very concerned about their reputation and their
performance.[36]
Is legislation required?
2.38
Some submissions argued that legislation is required to fix the
'problem'. Other submissions asserted there was a risk of regulatory overreach.
2.39
The AMWU argued that the imbalance in executive salaries 'must simply be
corrected to prevent – or at least stem – society's loss of faith in the social
entity of the corporation'.[37]
Indeed, the AMWU argued the further regulation is required in addition to this
bill:
...it is only one strand of a web of regulation that is necessary
to constrain the tendency of the corporation to act without concern or
acknowledgement of its responsibilities to the community in which it exists and
the workforce which generates its wealth.[38]
2.40
Professor Peetz noted that while there had been some reduction in
executive termination payments in recent years, for reasons including changing
economic circumstances and responsiveness by business to community sentiment,
further regulation was justified:
This bill is important not only for promoting good practice
in executive termination payments. It is also important that the parliament
send a signal that, like the community, it is no longer willing to welcome
excess in executive remuneration generally. While sending signals will not in
itself halt excessive remuneration, if parliament fails to pass this bill it
will send exactly the wrong signal and we could expect a return in the near
future to not only the excessive termination payments that characterised the
recent past but also the excessive growth in executive remuneration generally
that has been witnessed.[39]
2.41
Other submissions asserted there was a risk of regulatory over-reach. The
BCA described the bill as running 'the risk of significant regulatory overreach
with the potential to capture matters to do with the ordinary course of
business'.[40]
The BCA also argued:
A detailed discussion of the market problem at which these
proposals is aimed has not been provided in the Explanatory Memorandum. The
reforms are aimed at ‘curbing excessive termination payments paid to company
executives’ however there is little further explanation or evidence of market
integrity problems associated with that statement or explanation as to why
existing laws (e.g., remuneration disclosure, governance and non-binding
shareholder votes) are inadequate to address the issue.[41]
2.42
Other organisations asserting this risk include the Hay Group, the Australian Bankers' Association, the Australian Industry
Group, and ACCI.[42]
2.43
The Investment and Financial Services Association (IFSA) argued 'the current
governance regime over remuneration in Australia has experienced no systematic
failure even in the recent market turbulence. Evidence is growing that the
current regime is adjusting of its own accord to the changing financial
environment'.[43]
2.44
ACSI provided evidence that of the top 20 ASX companies, thirteen used
one year's base salary for termination payments for executive staff.[44]
However, as these companies were likely to be the most responsible due to their
size and concern for their reputation, ACSI still regarded legislation as
necessary to send a signal to the market (particularly smaller companies).[45]
2.45
Whilst BHP Billiton argued that reducing the threshold to 12 months'
base salary is 'too extreme',[46]
it acknowledged that the current thresholds in the Act 'allow for extremely
high pay-outs' and do 'not strike an appropriate balance'. The AICD also
'accepts that a reduction in the current shareholder approval threshold for
termination payments is warranted',[47]
although it too opposed the reduction to 12 months.
Committee View
2.46
Whilst many business submissions warned against the risk of over-regulation,
it is notable that none of the submissions received argued that termination
payments of up to seven years' total remuneration are appropriate.
2.47
Based on the evidence provided, the committee is persuaded that there is
a case for imposing further regulatory constraints on executive termination
payments.
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