gender pay gap reporting

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Gender pay gap reporting lewissilkinemployment.com

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Contents

What’s it all about?

Key definitions

What data needs to be gathered?

What calculations need to be made?

Further analysis

What to do now

What’s it all about?

From October 2016 relevant employers will have to report a number of

statistics about their relevant employees, as of the relevant date.

The statistics that employers will need to report are as follows:

• Mean gender pay gap

• Median gender pay gap

• Mean bonus gap

• Bonus proportions

• Quartiles

Reporting will need to be undertaken annually with statistics published on

the company website and left there for at least 3 years. The figures must

also be reported to the Government.

The Government has stated that it intends to use the figures to create a

league table, showing how they vary by industry.

Key definitions

(according to the draft

regulations)

02

Key definitions

Relevant employer

“a person who has 250 or more relevant employees on the relevant date”

Relevant employee

“a person (a) who ordinarily works in Great Britain; and (b) whose contract

of employment is governed by UK legislation”

Relevant date

“the 30th April 2017 and each subsequent anniversary of that date”

Pay period

“the period (a) in respect of which the relevant employer usually pays

that relevant employee, whether weekly, fortnightly, monthly or a longer

or short period; and (b) within which the relevant date falls”

Key definitions

Pay

“includes basic pay, paid leave, maternity pay, sick pay, area allowances,

shift premium pay, bonus pay and other pay (including car allowances

paid through the payroll, on call and standby allowances, clothing, first

aider or fire warden allowances)”

“does not include pay for a different pay period, overtime pay, expenses,

the value of salary sacrifice schemes, benefits in kind, redundancy pay,

arrears of pay and tax credits”

“is to be calculated before deductions for PAYE, national insurance,

pension schemes, student loan repayments and voluntary deductions”

Key definitions

Bonus pay

“payments received and earned in relation to profit sharing, productivity,

performance and other bonus or incentive pay, piecework and

commission”

“long term incentive plans or schemes (including those dependent on

company and personal performance)”

“the cash equivalent of shares on the date of payment”

Gross hourly rate of pay

“is determined using the weekly pay divided by weekly basic paid hours

for each relevant employee”

What data needs to be gathered?

Identify the entities

Will need to identify the number of UK entities which appear to employ

250+ employees (or which you expect to employ 250+ employees on the

relevant date)

Identify the “relevant employees”

Include all those with a contract of employment

BUT the Government has stated that it intends for a broader definition of

employee covering workers, self employed contractors and possibly

LLP members.

Do not include UK employees working overseas (e.g. overseas

assignments)

Include anyone who is employed in the pay period in question, but also

anyone who has received a bonus in previous 12 months

What data needs to be gathered?

Data needed for each employee

Male or female

Grade and department/function

Full time or part time (if PT their % of FTE)

Permanent or fixed term

Joined or left part way through year

The employee’s “pay period” (i.e. are they paid monthly, 4 weekly, 2 weekly,

weekly, etc. – and what is the precise period in which 30 April falls for each

employee)

Weekly contracted hours (in the case of salaried employees)

Actual hours worked during the pay period (in the case of waged employees)

Whether on maternity/paternity/shared parental/adoption/sick leave during the

pay period.

What data needs to be gathered?

Pay data

Basic pay/salary during the pay period

Maternity/paternity/ShPP/adoption pay

Sick pay during the pay period

Car allowance

Any area allowances during the pay period

Any other money allowances

Shift premium pay (i.e. for anti-social hours, working bank holiday etc.) (but not

overtime)

Any commission paid in the pay period

Any other bonus pay paid in the pay period

What data needs to be gathered?

Bonus data

General company bonus

Performance related bonus

Christmas bonus

Recruitment bounty

Sign on bonus

STIP, LTIP and all other incentive schemes – where shares are awarded, figures

need to be the cash value of the shares.

What calculations do you need to make?

A step by step guide

04

The calculations

Calculate the hourly rate

Divide the pay in the pay period by the hours for the pay period

Mean gap calculation

Find the mean for men by adding up all the hourly rates for men, divide by the

number of men.

Repeat for women

Calculate the mean gender pay gap by subtracting the mean women hourly rate

from the mean men hourly rate, dividing by the mean men hourly rate and then

multiplying by 100.

Median gap calculation

Find the median for men. Find the median for women.

Find the gap as with the mean above.

The calculations

Bonus calculation

Find the mean men bonus. Add up all of the bonuses received by men, divide

by the number of men who received bonus.

Repeat for women.

Calculate the mean bonus gap by subtracting the mean women bonus from the

mean men bonus, dividing by the mean men bonus and then multiplying by 100.

Bonus proportions

Calculate the percentage of men who received a bonus in the 12 months to 30

April, out of the total number of men using the following calculation

Repeat for women.

The calculations

Quartiles

Two possible

approaches and

interpretations of what

a “quartile” is – no clear

decision from

Government yet on

which is the correct

approach.

Approach 1 is the

statistical definition of

“quartiles” and seems

to be what Regulations

intend, but approach 2

has been referenced by

Government.

Calculate hourly rates for all.

Then, find the highest paid

relevant employee and the

lowest. Find the median. Find the

relevant employee between the

median and the highest paid, and

the median and the lowest paid.

You will have four equal sized

groups of employees. Calculate

the proportion of women within

each group.

Calculate hourly rates for all.

Then, find the highest paid

relevant employee and the

lowest. Use the highest and

lowest rates to create four

equally sized pay bands. Count

the number of relevant

employees within each pay band.

Calculate the proportion of

women within each pay band.

Approach 1 Approach 2

Further analysis

What other analysis could be

done to give context to the

reportable figures?

05

Further analysis

Questions to think about

What is the position if you look at the figures by job grade? What about job title?

How do the reportable figures compare to the national average? How do they

compare to the industry average?

The bonus figures do not take hours into account at all – what is the pro-rated

bonus gap?

How many are on maternity / paternity leave? What would be the effect on the

figures if their maternity pay was raised?

What is the gender make up at different levels of the organisation e.g. store

managers, area managers, etc? What is the pay gap at these different levels?

Further analysis

Questions to think about

How much does regionality affect the gap? I.e. if there are different rates paid

for the same role across the country, are more women working in lower paid

parts of the country than in higher paid parts e.g. London?

What is the pay gap by age? (ONS statistics say there is no gender pay gap for

under 40 year olds.)

Is length of service a factor? Is there a problem with staff turnover that is

affecting the reportable figures?

Is there an even gender split in the highest paying roles? If not, how would the

figures be different if there were?

What to do now

What can employers be doing

to prepare?

06

What to do now

Carry out a dry run using data for 30 April 2016

These figures will not be reportable and this provides an opportunity to see if

there will be problems in the future

Identify any areas of uncertainty over who is in scope

Think about employment status and who is a “relevant

employee”

Consider remuneration packages and benefits

Salary sacrifice could be used to reduce the value

Audit bonus schemes

Identify who will sign the statement confirming the accuracy of

the figures

Get your house in order

Thank you

Go to lewissilkinemployment.com

to find out more about our gender

pay gap reporting services,

or contact

[email protected]

All information contained within is correct as of 22 May 2016