10 BDO LLP | UK GENDER PAY GAP 10 BDO LLP | UK GENDER PAY GAP
Area
The Directive
UK Legislation
The Directive has differing thresholds for reporting frequency depending on employee headcount. Employers with: X More than 250 employees must report every year X Between 100 and 249 employees must report every three years X Less than 100 employees may report on a voluntary basis. The implementation of the Directive reporting timeline is likely to differ depending on the above thresholds. The Directive currently indicates that all workers are in scope providing they ‘have an employment contract or employment relationship as defined by law’. The Directive does not specify different treatment for workers who have received reduced pay due to absence. The Directive currently stipulates that compensation data (both ordinary and variable pay) relates to the 12 months of the previous calendar year. The Directive provides a brief overview regarding the classification of pay elements. Specifically, it provides details about what pay elements fall into variable pay: bonuses, overtime compensation, travel facilities, housing and food allowances, compensation for attending training, payments in the case of dismissal, statutory sick pay, statutory required compensation and occupational pensions.
GPG reporting is only a requirement for entities with at least 250 employees in England, Scotland and Wales on the relevant snapshot date.
Reporting criteria
Classification of employees
Ordinary pay data relates to the pay period in which the snapshot date falls, while variable pay data relates to variable pay received in the prior 12 months ending on the snapshot date. People with a contract of employment with the Company, including if they work part-time, job-share, on leave, apprentices, certain types of contractors, and certain non-GB based individuals are all in scope. The UK legislation further categorises in scope workers into two buckets: full pay relevant employees (relevant for ordinary pay gap analysis) and relevant employees (relevant for variable pay gap analysis). Ordinary Pay: Basic pay, cash allowances, piecework payments, holiday and leave pay, shift premium pay. Bonus Pay: Generally irregular or one-off payments (commission, exam awards, profit sharing, bonus, recognition, LTI payments and vouchers). Excluded: Overtime, related payments and on-call payments, Pension contributions, pay relating to leaving, non-cash benefits, Interest free loans, payments relating to other pay periods and business expenses.
Data period
Classification of pay
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