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Gender pay gap

Creating a narrative

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What is the aim of this guide?

What to include in the narrative?

1. Starting your Gender Pay Gap Report • What is the legislation: Under the Equality Act 2010 (Specific Duties and Public Authorities)

Regulations 2017, all organisations listed at Schedule 2 to the regulations that employ over 250 employees are required to report annually on their gender pay gap. Other organisations with 250 or more employees will need to comply with the Equality Act 2010 (Gender Pay Gap Information) Regulations 2017.

• What does gender pay gap mean: The gender pay gap is a high-­level snap-­shot of pay within an organisation and shows the difference in the average pay between all men and women in a workforce. If a workforce has a particularly large gender pay gap, this can indicate there may a number of issues to deal with, and the individual calculations may help to identify what those issues are.

In contrast, ‘equal pay’ is a more specific legal concept that deals with the pay differences between men and women carrying out comparable jobs. Men and women in comparable jobs are normally

This publication is intended to provide suggestions and assist organisations to publish their gender pay gap data. Although a narrative is not a mandatory requirement when presenting your gender pay gap calculations, we strongly recommend you explain where and why your organisation has gaps, the reasons for this and what your organisation is doing to tackle the causes.

We have set out steps for HR professionals to follow when drafting their gender pay gap report.

o Explanation of the reason for any pay gaps. For example a high proportion of one gender in lower grades.

o Strategy: D&I, pay, talent o Benchmarks, for example from year two onwards comparison to previous years o Update on what you have already done to reduce pay gaps o Action plan – what are you planning to do to reduce any pay gaps as a result of this

analysis [DN: Remember this will be publically available for at least three years.]

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entitled to the same pay unless an employer can show differences in pay are justified. A gender pay gap does not equate to the existence of an equal pay problem, albeit a gender pay gap may be a trigger for further investigation about the reasons why the gap exists.

• What is required:

% 1. Mean gender pay gap -­ Ordinary pay 2. Median gender pay gap -­ Ordinary pay 3. Mean gender pay gap -­ Bonus pay in the 12 months ending 31 March 4. Median gender pay gap -­ Bonus pay in the 12 months ending 31 March 5.The proportion of male and female employees paid a bonus in the 12 months ending 31 March:

Male Female

6. Proportion of male and female employees in each quartile.

Quartile Female % Male % First (lower) quartile

Second quartile

Third quartile

Fourth (upper) quartile

2. Organisational context • What is your approach: Discuss the strategic approach the organisation is taking forward, making

reference to the diversity & inclusion strategy, including mission statements or aims/objectives that the organisation wishes to achieve in this area. Greater transparency and accountability is key to enable organisations to demonstrate their commitment to equality – attracting talent and boosting staff engagement. (see Annexe A)

• What is your organisational structure: Talk about the composition of your organisation – name the executive agencies that you sponsor and have included in your gender pay gap calculation. Alongside your overall gender pay gap figures, you may wish to include a separate breakdown of your data by core department/executives agencies. You could discuss the percentage of men and women in the workforce and give details of the grading structure and relevant pay ranges, if applicable. (See Annexe A)

3. Representing your data • What data do we need to include: Salary data used for this report is based on employee pay on

the snapshot date of 31 March 2017 as well as bonus pay between 1 April 2016 and 31 March 2017. You should also include data from executive agencies that are sponsored by your organisation. Here you should also offer an explanation of what data has not been included in your gender pay gap report and the reasons for this.

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Recruitment, retaining and developing a diverse workforce

Career paths

Progression

• Comparing Methodologies: The Office for National Statistics (ONS) is the UK's largest independent producer of official statistics and the recognised national statistical institute of the UK. Each year ONS undertakes two surveys and the published outputs include gender pay gap statistics. These are: · Annual Survey of Hours and Earnings (ASHE) · Annual Civil Service Employment Survey (ACSES). It is important to note that the two surveys use very different methodologies. ASHE uses employee’s actual earnings, excluding overtime, and actual working hours during a specified pay period. ASHE uses this data to calculate the hourly rate which is used to calculate the gender pay gap. ACSES uses employee’s full time annual equivalent pay, excluding bonuses. This annual figure is used to calculate the gender pay gap. ACSES does not collect contracted hours and therefore, does not calculate hourly rate.

• How can we represent the data: Visuals can be used to represent your data and present your

gender pay gap through a more informative method. (See Annexe A)

• How can we represent the data for different entities: You are encouraged to present your data separately for executive agencies to show more clearly where the gender pay gaps can be found, particularly where there are separate pay/grading structures to the parent department. These can be presented in whatever way you feel is best – infographic style, pie charts, tables etc.

4. Closing the Gender Pay Gap Below we have provided actions your organisation could use to tackle and reduce the gender pay gap.

• Ensuring a gender balance on appointment panels. • Developing and carrying out non-­discriminatory job descriptions and analytical job evaluations

that are flexible enough to meet the business’ needs. • Name blind recruitment. • Organisations moving to a ‘flexible by default approach’ to all recruitment

• Developing and running leadership development programmes to encourage career progression of female staff.

• Providing access to mentoring, shadowing and coaching to encourage and promote progression into senior roles.

• Providing women with enhanced opportunities for training and development.

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Family friendly

Learning and development

Performance management

Pay systems

• Talent programmes supporting the right people into the right roles providing access to the right opportunities, exposure, stretch and development to reach their potential. For instance, Future Leaders Scheme, Positive Action Pathway, Civil Service Fast Stream, Prospectus Programme and Apprenticeships. Also, for SCS Senior Leaders Scheme, Leading to Inspire and High Development Scheme.

• Career break returner programmes supporting employees after career breaks to boost skills offering paid placements between six weeks to six months including learning and developments opportunities. The returner programmes are open for both genders but are expected to help women who have taken time out to bring up children or for other caring responsibilities.

• Review performance management processes, identify areas of risk and develop training programmes to ensure appraisals are conducted fairly.

• Examine the pay structures to undertake an equal pay audit.

• Extend and support learning and development on equality training and diversity;; focusing on occupational segregation and unconscious bias training, diversity and equality courses, LGBT and disability confidence

• Ensure that employers explore modern working practices that can offer staff greater flexibility. Home working, job-­sharing and part-­time.

• Facilitate, encourage and support shared parental leave and focus on outcomes rather than the time spent in the office.

5. Conclusion

• Declaration: The public sector regulations do not specify what sign –off is required for the gender pay gap data. However, internal governance routes should be followed which may require sign off. This could be, for example, the Permanent Secretary or HR Director. Additionally, some organisations have included a signature and name for a person who has signed off the declaration/report.

• Measuring outcomes after reporting period: The impact of any strategies developed will be negligible unless a monitoring process is established to measure progress against the actions plans. These strategies will need to be reviewed and reassessed in light of mergers or any other changes in the corporate structure of the organisation.

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[The following is an example of the type of narrative that may be considered. Care needs to be taken to ensure that the narrative reflects the organisation and its

initiatives/positions/priorities etc.]

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Annexe A Reference to the legislation

Organisational Context

Organisation Structure

‘Gender Pay Gap legislation (developed by the Government Equalities Office) introduced in April 2017 requires all employers of 250 or more employees to publish their gender pay gap for workers in scope as of 31 March 2017. The department for Education’s (DfE) pay approach supports the fair treatment and reward of all staff irrespective of gender’. DfE

‘DfE uses Civil Service grades ranging from Executive Assistant (adm. level grade) to Senior Civil Servant (executive level grade). Grades vary according to the level of responsibility that staff have. Each grade has a set pay range with pay gaps between grades. Staff are expected to move through the pay range for their grade, therefore the longer period of time that someone has been in a grade the more we would expect them to earn irrespective of their gender’. DfE

‘This year, for the fist time UK companies, with over 250 staff, have to report on their gender pay gap’. TSB

‘Acas’ pay approach supports the fair treatment and reward of all staff irrespective of gender’. ACAS

‘PWC believes in being an inclusive and diverse organisation where anyone can reach their full potential. We were the first professional firm to voluntary publish our gender pay gap in 2014 and this will be our fourth year of doing so’. PwC 2017

‘We’re a different kind of bank with transparent, diverse, and inclusive culture. This is not about promoting one group of people above another, but about ensuring everyone, regardless of their background, race, ethnicity or gender, has an equal opportunity to thrive. We want to create a bank that attracts and retains the best people and reflects the communities we serve’. TSB

‘We are passionate about fairness, equality and inclusion and committed to reducing out gender pay gap’. Virgin Money

‘Doncaster Council is committed to the promotion of equality of opportunity and choice for all employees. A diverse and inclusive workforce isn’t just good for women – it’s good for everyone’. Doncaster Council

‘ACAS’ pay system covers Civil Service grades ranging from administrative to managerial level. Grades vary according to the level of responsibility that staff have. Each grade has a set pay range with pay gaps in between grades. Staff are expected to move through the pay range for their grade. The longer period of time that someone have been on the grade the more we would expect them to earn irrespective of their gender’. ACAS

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How to represent your data

DfE

Virgin Media

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ACAS

Doncaster Council

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Representing the data for different entities

SSE

PwC

Declaration

‘We confirm that Deloitte’s gender pay gap calculations are accurate and meet the requirements of the Regulations. The calculations, data and assertions contained in this announcement have been fully assured by the Deloitte’s Sustainability Team , who have confirmed that the methodology provided in The Equality Act 2010 (Gender Pay Gap Information) Regulations 2017 has been applied correctly’. Deloitte’s declaration

‘PwC has two employing entities within the group. Employment between these two entities is largely driven as a result of historical mergers and acquisions. All new employees join PwC Services Limited. Under the gender pay gap reporting regulations we are required to provide information for both these entities which is set out below’. PwC

‘We confirm that our data has been calculated according to the requirements of The Equalty Act 2010 (Gender Pay Gap Information) Regulations 2017’. Capgemini’s declaration

‘We confirm the data reported is accurate’. PwC’s declaration