Gender Pay Gap Reporting
Lewis Silkin can advise large employers on producing their first gender pay gap reports by April 2018 at the latest, based on payroll data from April 2017.
Properly structured, this can be conducted on a legally privileged basis allowing employers to plan for how to address difficult issues raised by the results without creating disclosable documents. We understand that addressing the gender pay gap is also about wider HR and employment relations issues such as hiring, promotion and appraisal processes. We are ideally placed to help you develop and implement an action plan addressing all relevant legal, HR, practical and operational challenges.
Key steps for employers include the following:
- working out if you are in scope. A legal entity with 250 or more ‘relevant employees’ will have to report its gender pay gap. If you are part of a group of companies, multiple entities may need to comply. Pending clarification in the final version of the regulations, ‘relevant employees’ could include not just ‘ordinary’ employees, but also other types of workers and even some self-employed contractors
- trialing the process. Employers should consider a “dry run” to get an idea of what they will need to report. This in turn will allow them to consider what factors might be generating any pay gap or skewing their figures, and what narrative they could include in their report to put gender pay gap statistics into context
- change your pay practices to improve your statistics. A range of steps should be considered. Would managers benefit from clearer guidance on how to make decisions on salary reviews and bonuses? Should managers attend unconscious bias training? Are appraisals structured in such a way as to control for gender bias? Could programmes to encourage the career development and progression of female staff be developed or improved upon?