Gender pay gap regulations are expected to be approved by Parliament any day now and will commence from April 2017. At this point, employers will have up to 12 months to publish their gender pay gap information. Our Autumn Roadshow and discussions with clients have observed a mixed picture in terms of what companies are or aren’t doing in preparation for the upcoming legislation.

On the one hand, a number of large employers have signed up to gender equality initiatives such as the Women in Finance Charter, which seeks to address the underlying issues of inequality in senior positions. HSBC, Santander, Lloyds and RBS have committed to having women fill at least 30% of senior roles by 2021. An additional 13, including Legal & General and Virgin Money, are aiming for an equal split between men and women in senior posts.

However, an alarming number of companies with 250+ employees simply haven’t examined their headline gender pay gap yet. While the official regulations are yet to be announced, they’re unlikely to deviate much from the draft outline. The move to conducting a gender pay investigation is a step that all sizes of employer should take, if not for publication then for their own internal records. The results will help them start thinking about how they will create a narrative for existing and prospective employees.

So, why are we waiting?

Employers who haven’t yet started working towards uncovering their headline gender pay gap, could be putting it off for a number of reasons:

• “What’s the point until regulations come out?”
• “We are fine; we don’t have an issue with gender pay.”
• “We have fewer than 250 employees, so we don’t need to worry.”
• “We don’t have the resource to devote to it.”

Not everyone is waiting…

We’re already helping several clients produce mock pay audits ahead of the legislation. The good news is, the data gathering exercise is relatively straightforward. It allows clients to lay the groundwork for real reporting when the time comes, as well as identifying gaps in their data that will need filling in. These are the initial steps we take clients through to fulfil the regulatory obligations:

1. Gather the basic data (e.g. employees in scope, payroll ID, job title, gender, working hours, current actual salary and last bonus paid)
2. Download our free gender pay calculator
3. Upload your data
4. Review the outputs
5. Summarise your headline gaps

But this is just the first part of the process. Digging below the surface of the reporting figures and understanding the detail of the story is key to addressing the causes of your gender pay gap and developing your gender pay story. After completing the initial gender pay audit, we advise clients to undertake these stages:

Uncovering risk: One of the main concerns of organisations is that publishing their gender pay gap is likely to cause disquiet and uncertainty among employees. It’s possible that ‘no win no fee’ lawyers will target high profile firms with a large gender pay gap, to encourage female employees to bring an Equal Pay claim against their employers. Further discovery work and a full Equal Pay Audit, where you can compare males and females doing the same work and equal value, will help identify and resolve risk and protect against legal claims.

Taking control: Any organisation’s aim should be to improve gender pay gap results over time. Developing and tracking key metrics will help show where current policy and practice may be subtly driving differences which build over time.

Leading the way: Building an organisation that employees can be proud of is key to engaging, attracting and retaining talent. Creating a clear narrative around gender pay with a richer context than just the headline figures, helps demonstrate commitment to improvement.

If you have been waiting to get started on your gender pay gap analysis, get in touch to find out more about how we can help: 020 3457 0894.

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