Gender Pay Gap Reporting - CIPP policy whitepaper


Challenges and concerns

There were many issues highlighted in comments by survey respondents; the comments chosen represent multiple concerns across these areas:

“We are concerned about the queries we may receive from clients and their expectations. Due to the gender pay gap legislation rules being so late, payroll software could only produce so much [limited] support in the early days.”

“Ordinary pay is calculated after salary sacrifices are excluded. This reduces the amount which is taken into account in the comparison. This has a greater effect on female hourly rates of pay than on male as women are more likely to take advantage of the childcare voucher salary sacrifice scheme.”

“ The guideline tells you to exclude the very people the whole thing is designed to document and then focus on helping - people on long-term leave. This removes people on maternity leave - surely the point is to include these people and any pay rise they have whilst on leave.”

“Guidance on what is reduced pay and absence needs to be clearer, especially for people on half pay.”

“Trying to work out hourly pay accurately in a boarding school environment has been extremely difficult and time consuming.”

“The media do not fully understand gender pay gap so figures are being mis-represented in news.”

“I am concerned that data at the snapshot date may not give a true picture of average hourly rates, given it included a variety of additional payments (shift allowances etc.). It also asked for on-call hours to be included, which depended on whether the individual was asleep or not. This information was impossible for us to obtain.”

“Why are bonuses included in the hourly rate on the snapshot date when they are dealt with separately over the previous 12 months? Could salary sacrifice be included if the top line salary is still used for other purposes i.e. overtime rate?”

Further to our surveys there have been many more carried out; more recently the Governance Institute ( ICSA ) have published results on a recent ‘quick question’ survey which asked Are you considering taking action following preparation of your gender pay gap report? 32% said yes closely followed by 28% who said no and 40% were undecided. However comments made confirmed concerns raised throughout our research and indeed throughout the last year ‘…it had been costly. ‘It has required additional management time and resources to compile and review the data,’ said one respondent. Another said: ‘The identification of data and the narrative to contextualise that data has been resource-intensive.’

Many respondents to this research believe the process will shame disobliging firms into reducing the pay gap. ‘Naming and shaming will drive active management of the issue,’ one respondent said. ‘What gets measured gets managed!’



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