In Summer 2015, the Government Equalities Office (GEO) published a "principles-based" consultation seeking views on the key points which would underpin the new gender pay gap reporting regime. Here we round up where the Government has got to with the new gender pay gap reporting legislation and summarise the work that AG's Employment team has done on this agenda in the last 6 months.
That consultation closed on 6 September 2015 and the Government published its response on 12 February 2016. You can read our report on the response here. The response confirmed that employers with 250 or more employees will have to publish the following "gender pay information" on an annual basis:
- Mean and median overall pay gap figures (including bonus, commission, LTIPs and the cash value of shares).
- Mean bonus gap figures.
- The proportion of men and women who received a bonus payment within a 12-month period.
- The numbers of men and women paid across salary quartiles within their business.
The response confirmed that the regulations are likely to come into force on 1 October 2016, with a first reporting date of not later than 1 April 2018. At the same time, a second consultation covering the details of the draft regulations was published. That second consultation closed on 11 March 2016, and the Government's response is awaited.
Over the last six months, Addleshaw Goddard's Employment team has worked with the GEO and clients on this agenda:
- On 15 October 2015, we spoke alongside one of the lead policy managers from the GEO, Sara Abbonizio, and the Head of Talent at Deloitte LLP, Emma Codd, at our Annual Employment Seminar. That session considered the aims of the new transparency regime, the options for how it would operate, and Deloitte's experience of voluntarily reporting their gender pay gap in Summer 2015.
- On 8 February 2016, we attended the "Trailblazing Transparency" reception co-hosted by the GEO and Deloitte LLP, at which the Minister for Women and Equalities, Nicky Morgan MP, discussed the purpose of the new regime.
- On 24 February 2016, our Employment PSL, Amanda Steadman, was interviewed by Lexis PSL on what the new regime means for employers. You can read the article, "Bridging the pay gap" here.
- Also in February 2016, we worked with a number of clients to produce a response to the second consultation on the draft regulations.
- On 10 March 2016 and 7 April 2016 we held round table Breakfast Seminars in our London office, attended by a variety of clients across a range different sectors. At these seminars we analysed the new regime and considered what steps employers should be taking to prepare. We were delighted to co-present these sessions with Gapsquare an organisation providing free tools to help employers analyse their data and measure their gender pay gaps.
- On 2 March 2016 and 13 April 2016 we also held seminars in our Leeds and Manchester offices for HR professionals representing a range of sectors, where we discussed the new regime.
- We are also providing bespoke training and advice for a number of clients on the new regime. In particular, a number of clients have expressed interest in conducting a "dry run" gender pay gap analysis to understand their pay gap figures prior to the introduction of the new rules. We have advised how to approach this and how to attract legal privilege around such exercises.
If you would like to discuss how gender pay gap reporting will work in your business, please contact either your usual AG contact, or Amanda Steadman.