What to include in a gender pay gap report narrative

The gender pay gap reporting deadline is fast approaching. The last possible day for publishing the information is 30 March 2018 for public sector employers (including maintained schools and academies) and 4 April 2018 for all other employers (including independent schools). But what if there is a gap? Having a gender pay gap does not necessarily mean that the employer has acted inappropriately or in a discriminatory way. An accompanying narrative can help to explain this.

Employers are free to choose whether to add an accompanying contextual narrative to their report but we suggest it is advisable. Acas (the workplace information and advice service) has confirmed this in its helpful guide entitled ‘Managing gender pay reporting’ (produced in conjunction with the Government Equalities Office) which can be found here (“the Guide”). A narrative helps anyone reading the statement to understand the organisation’s view of why a gender pay gap is present and what the organisation intends to do to close it.

The narrative and the reasons behind the gender pay gap will be specific to each organisation, but it may be appropriate for the narrative to:

  • Explain the key reasons for the organisation’s gender pay gap;
  • Confirm measures are in place to reduce the gap, for example by setting out the actions that the employer will take to help close the gap such as reviewing staff bonus schemes; recruitment processes; mentoring / sponsorship initiatives; and career development opportunities;
  • Explain the measures that, although are already in place to reduce the gap, will take some time to take effect, or will increase in effectiveness over the years. This helps to show that the organisation is taking action to reduce the gap but demonstrates that it takes time to bed in;
  • Explain where the gap has reduced over time; and
  • Explain how your figures compare with the gender pay gap of others within the sector or in the wider economy.

As the narrative is likely to list the actions that the employer intends to take to reduce the gap, it may be beneficial to consult any recognised trade unions about the action plan (prior to publication of the narrative). Likewise, employees should be given the opportunity to contribute to any action plan. The employer could initiate these discussions in team meetings, suggestion boxes and focus groups.

The gender pay gap report will undoubtedly be an important reputational tool. A survey by Business in the Community found that:

  • 93% want to see their employer’s pay gap;
  • 92% said they would use this information if they were looking for a job and deciding between two employers; and
  • More than half of female employees would favour a company that was more proactive in closing their gap.

As the gender pay gap information must be published on the employer’s website (and so is accessible to all), a considered, appropriately drafted narrative is a useful way to reassure current and prospective employees that the organisation is moving in the right direction.

The law and practice referred to in this article or webinar has been paraphrased or summarised. It might not be up-to-date with changes in the law and we do not guarantee the accuracy of any information provided at the time of reading. It should not be construed or relied upon as legal advice in relation to a specific set of circumstances.

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