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ISSUE 6
who use salary survey levels as ‘grades’ are likely to need to take action.
“ The regulations are seen by many as the end of ‘discretionary’ reward practices because such schemes will struggle to be compliant. ” by clear, robust and documented processes – e.g. using robust market data gathered using a consistent process (Please note: market data from sources such as Glassdoor is unlikely to be considered robust). include the existence of market premia or individual performance differences. Both of these potentially valid justifications need to be underpinned Communicating pay relativities Employers need to put systems into place to enable them to share the required information e.g. information on individual employee pay levels and the average pay for male and female workers performing the same jobs as them or work that has been rated as ‘equal-value’. Others… There are a number of additional steps that employers will need to take in preparation e.g. communicating the gender pay gap where employee minimum numbers are met, reviewing recruitment practices, training managers to respond to employee questions, reviewing employment
Communicate reward strategy The new regulations require sharing information on how pay is set, managed and progressed with employees, essentially requiring the publication of large parts of your reward strategy. As a result, it may be a good idea to review and redraft your reward strategy now to ensure it is up-to-date and ready for wider communication. If you are communicating this with employees, you should also expect it to cross the desks of your competitors so you might want to consider your wording in this context too! Removing management discretion The regulations are seen by many as the end of ‘discretionary’ reward practices because such schemes will struggle to be compliant. For example, bonus schemes which give leaders a pot of money to share amongst employees as they see fit will need redesigning to give more structured guidance on how to allocate the funds. Guidance that should also be shared with employees at the start of the performance period. Justifying individual pay differences The regulations do not require all employees in the same role to be paid exactly the same amounts and there is still room for pay differentiation but employers need to show it is based on objective and clearly non- discriminatory criteria. This could
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