If you are a housing association which had 250 or more employees on 1st April 2017, you are required under The Equality Act 2010 (Gender Pay Gap Information) Regulations 2017 to produce a Gender Pay Gap Report by 4th April 2018.
As of 22nd December 2017, only 470 employees in the UK had published their Gender Pay Gap Reports, four of which were HAs. This suggests there is huge amount of work for many HAs to complete by the 4th April 2018 deadline.
The Equality and Human Rights Commission (EHRC) published its enforcement strategy in mid-December 2017 which summarised their approach to enforcing compliance with the regulations. The EHRC will approach randomly selected non-compliant employers within each industry, giving them a final notice to comply. Where employers fail to respond or report within the given deadline, the EHRC will carry out formal investigations, and the employer could face unlimited fines. The strategy also reveals that action may be taken against employers for publishing inaccurate data.
HAs are required to report the following data:
- The average gender pay gap as a mean average
- The average gender pay gap as a median average
- The average bonus gender pay gap as a mean average
- The average bonus gender pay gap as a median average
- The proportion of males receiving a bonus payment and proportion of females receiving a bonus payment
- The proportion of males and females when divided into four groups ordered from lowest to highest pay.
Employers have the option to provide a narrative in their reports, which can explain the reasons for the results and provide details about what actions are being taken to reduce or eliminate the gender pay gap.
The report should be signed by an appropriate person (e.g. Chief Executive). HAs are then required to publish the information on their own websites as well as the Government website: https://www.gov.uk/report-gender-pay-gap-data.
Anyone can look up the Gender Pay Gap Reports for any company required to publish this information. It is available at a viewing service on the Government website: https://gender-pay-gap.service.gov.uk/Viewing/search-results.
HAs need to consider the impacts of failing to report this information by April 2018, or if they report large variances in gender pay:
- Enforcement action and unlimited fines from the EHRC
- Challenges attracting prospective employees
- Detriment to employee engagement / satisfaction / retention
- Potential equal pay claims
- Negative media exposure and damage to reputation
- Impact to union relationships
- Requirements to provide the data for tenders or accreditation assessments
An important question that HAs should be asking themselves is, are we ready to meet the reporting requirements by April 2018?
Altair provides a Gender Pay Reporting service – producing reports for organisations, identifying any gender pay gaps and providing bespoke recommendations designed to reduce gaps. Our team at Altair are uniquely placed with specialists in employment law, and reward and remuneration.
Altair also supports Leadership2025 a development programme for senior leaders from BME backgrounds. Leadership Diversity Champions are organisations who have agreed to implement “The Altair Review” by signing up to a five point plan to create more ethnically diverse leadership across the sector. To find out more visit Leadership2025
Altair also provides wider HR consultancy services for housing sector clients across the UK and Ireland. For more information, contact Kimberley Wallace HR Consultant at Altair on 07585 954 218 | firstname.lastname@example.org.