Raffles Consulting Services
Family office employment records should connect each person to the employing entity, real duties, payroll, work-pass status and investment work.
Family office employment records should show who employs each person, what work the person actually performs, where the person does it and how the team handles salary and statutory obligations. A title on an organisation chart is not enough. The contract, payroll, work-pass record, decision papers and day-to-day output should tell the same story.
This matters when a family office relies on Singapore management, investment professionals, local spending, regulatory representations or work passes. Maintain the evidence during employment instead of assembling it only when an application, renewal or annual review begins.
Start with the legal employer
The EDB single family office guide says families should build a team for the SFO and fund entities and identifies investment-professional conditions for Sections 13O and 13U. Decide which entity needs the role and which entity will sign the employment contract, pay salary, direct the work and hold the employment records.
A person may support several family entities, but the entities should document the arrangement. Record the primary employer, reporting line, permitted secondment or service arrangement, cost allocation and time split. Avoid showing the person as a full-time employee of two entities for the same hours.
Where an approved incentive or regulatory condition uses a defined term such as investment professional, test the current legal and approval requirements. A family relationship, senior title or board seat does not by itself prove that the person meets the condition.
Keep a role file based on actual work
Write the job description around decisions and outputs. For an investment role, this may include research, manager selection, portfolio monitoring, risk review, trade or commitment recommendations and investment reporting. For an operations role, it may include accounting, governance, cash control, administration or compliance.
Retain dated examples such as investment papers, meeting minutes, risk reports, manager reviews, approval records and completed projects. Protect confidential information, but keep enough evidence to demonstrate the work. Do not present attendance at a family meeting without substantive responsibility as an investment function.
| Evidence area | Record | Mismatch to investigate |
|---|---|---|
| Employer | Signed contract, board approval and payroll entity | Salary paid by an entity not named in the contract |
| Duties | Job description and dated work output | Investment title with only personal or administrative work |
| Reporting | Organisation chart, manager and appraisal | No one reviews performance or assigns work |
| Presence | Work location, leave and travel records | Singapore role performed mainly elsewhere |
| Pay | Payslips, bank payment and general ledger | Large reimbursements or fees outside payroll |
| Status | Work pass or CPF record where applicable | Occupation, salary or employer does not match |
Maintain the employment and salary records
MOM’s employment-record guidance requires employers to maintain detailed employee and salary records for employees covered by the Employment Act. Employers must keep a current employee’s latest two years of records. They must retain a former employee’s last two years of records for one year after the person leaves.
The records include identity and work-pass details for non-citizens, employment dates, working hours and leave. Salary records include the salary period, basic salary, allowances, other payments, deductions and net salary. Family offices should also keep the employment contract, variations, confidentiality and conflict terms, benefits, expenses and termination records.
Payments should have clear labels. A director’s fee, family distribution, loan, expense reimbursement and salary have different purposes. Combining them in one transfer makes the reason for the employee’s pay harder to explain.
Reconcile CPF or work-pass evidence
The CPF Board explains that employers use their CPF Submission Number to submit contributions and must pay contributions by the stated deadlines for eligible employees. Reconcile the payroll register, bank payment, CPF submission and general ledger. Investigate missing months, incorrect identity numbers and unexplained differences.
For a foreign employee, compare the contract with the work-pass employer, occupation and salary. MOM requires an employer to notify changes to an Employment Pass holder’s salary and provides a separate process for occupation changes. Moving a person to a related entity normally requires a new pass for the new employer rather than an internal accounting entry.
Keep renewal dates and passport expiry in the employment calendar. Do not wait until a tax-incentive review to discover that the pass or recorded occupation no longer matches the relevant role.
Document related-party pay and conflicts
A family member can be a genuine employee, but family ownership makes approval and market evidence more important. Record who approved the role and remuneration, the basis for salary and bonus, any conflict declaration and the person’s performance review. An independent director or committee member may need to review the arrangement.
Suppose a founder’s adult child joins the Singapore SFO as an investment analyst. The file should include a contract with the SFO entity, a job description, reporting line, market pay paper, work-pass or CPF evidence, monthly payroll and investment work such as research notes and committee materials. Family membership explains the relationship, not the employment duties.
Run a quarterly person-to-entity reconciliation
List every employee and contractor across the SFO, fund vehicles and service entities. For each person, compare legal employer, work-pass sponsor, payroll account, CPF submission, cost centre, supervisor, duties and external appointments. Resolve differences and decide whether the entities need a service agreement or secondment.
Review departures promptly. Remove bank and system access, recover records, update authorities, keep required employment evidence and decide who will cover the role. Where the person’s work supported an incentive or regulatory condition, assess the effect before treating the vacancy as an ordinary human-resources matter.
Our investment-professional guide explains the role question, while the family reporting guide covers management information. The family-office governance guide is the cornerstone, and the Family Office and UHNW Advisory hub connects the wider operating model.
The best evidence is ordinary and consistent: the right entity employs the person, payroll follows the contract, records meet Singapore requirements and the work product proves what the person actually does.