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Having now (hopefully) submitted your 2022 gender pay gap report in advance of the 4 April deadline, you are likely to be looking to next year’s report (5 April being the 'snapshot date’ for the pay period used to gather the relevant data). You should be able to see from the report you have just published how your organisation is currently faring in relation to the gender pay gap, but where do you want, and need, to be in the future? It is not enough just to file your report and move onto the next item on your EDI 'to-do list’. What tangible, practical steps are you taking to close the gap in your organisation? Below, we look at how employers can actively drive meaningful change.

Reminder of your obligations

Broadly speaking, the gender pay gap measures the difference between the average earnings of men and women. Under the Equality Act 2010 (Gender Pay Gap Information) Regulations 2017, private companies with 250 or more employees must publish a gender pay report which includes specific calculations. Tuesday 4 April marks the deadline for companies to publish their 2022 gender pay gap reports and Wednesday 5 April is the ‘snapshot’ date for the pay period used to gather data for next year’s reports.

Remember that it is a legal requirement for all affected employers to comply with the Regulations and publish their gender pay reports. The Equality and Human Rights Commission (EHRC) can take enforcement action in the event of a breach of the reporting requirements.  Non-compliance can also result in reputational damage as the EHRC publishes details of any employer that it investigates on its website.

Watch our short video for a reminder of what information employers need to include in their gender pay gap reports and where and how those reports must be published. 

Create an action plan

When publishing a gender pay report, employers have the option of providing an additional narrative to put their pay data into context. In addition, some employers choose to publish an action plan, setting out specific targets they are committed to achieving within a chosen time frame. Publishing an action plan offers a useful opportunity to explain to stakeholders and employees how you are planning to tackle the specific gender pay gap challenges facing your organisation, as well as demonstrating your commitment to achieving this.

Positive steps to drive improvement

Whether or not you choose to produce an action plan and make it public, now is a good time to reinvigorate any initiatives you have already put in place to reduce the gender pay gap within your organisation and take further steps to drive improvement. Issues for HR to consider include:

  • Can you improve your recruitment practices? For example, have your managers and HR received training on unconscious bias?  Are your job advertisements drafted in an inclusive way so as to encourage a diverse range of candidates to apply?  Are your recruitment panels gender-balanced? Could you adjust the tasks you ask candidates to undertake as part of your recruitment process to be more skills-based (as unstructured interviews tend to be more prone to bias)?  
  • Can you improve your other diversity and inclusion strategies? For example, have all of your staff received diversity training?  Does your organisation promote a zero-tolerance approach to bullying and harassment?  
  • Could you offer more flexible working opportunities? This issue is likely to evolve significantly with the introduction of the Employment Relations (Flexible Working) Bill. This Government-backed Bill aims to amend the process for requesting flexible working in various respects, including making the right to request flexible working a “day one right”, see here. Query too whether you could make clearer in your job adverts when roles could be undertaken flexibility, with the aim of encouraging a wider pool of talent to apply. Currently, the proportion of job adverts offering any flexible working remains low, which means many good candidates who require flexibility often do not feel able or encouraged to apply. Developing your HR policies and practices to better help employees balance work and caring responsibilities is likely to indirectly benefit women.
  • Could you offer better support to working parents and carers? Are your family-related leave policies up-to-date and do they go far enough to support working parents?  Do you actively promote your shared parental leave scheme? Would your managers benefit from training or written guidance on how to support parents who are returning to work following a period of family-related leave?  
  • Can you improve the representation and progression of women across your organisation? Could you offer better access to development opportunities (perhaps by setting up a women’s network)? Do you offer mentoring and coaching (including “reverse mentoring”, where senior employees are mentored by more junior staff)?  
  • Is your senior leadership team genuinely invested in improving your gender pay gap? If not, how can you better engage them to drive meaningful change?   

Benefits of looking ahead

Failure to take positive steps to improve equality, diversity and inclusion can have significant negative consequences from both a public reputation and an employee relations perspective. By the same token, showing that you are taking active steps to tackle gender pay gap challenges in your organisation can reap significant reputational rewards, help to attract a wider talent pool, improve staff retention and boost employee morale. It is, of course, important to be realistic as effecting cultural change across any organisation takes time. Creating a clear action plan in which you set focused targets which are specific to your organisation should help you to achieve your aims. 

How we can help

Make UK’s HR consultancy team can provide a Visioning Workshop. This is a tailored strategy planning session during which we can help to analyse your gender pay gap data and explore what steps your organisation could take to tackle the specific gender pay gap related challenges you are facing. 

We also offer a broad range of EDI+ products and services, including a collection of micro-videos showcasing expert content on topics such as bullying and harassment, unconscious bias and allyship, to help you to create an inclusive workforce.

If you are a Make UK subscriber, you can also speak to your regular adviser. If you are not a Make UK subscriber, our expert HR and legal advisers can offer guidance on a consultancy basis. For further information, contact us on 0808 168 5874 or email [email protected].

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