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Are you ready for Gender Pay Reporting?

The deadline for publishing gender pay data is less than four months away. Yet, at the time of writing, only 366 out of roughly 9,000 companies legally required to report have submitted their numbers. That is less than 5 per cent. Chances are, many of our readers still have gender pay reporting on their ‘To Do List’ for 2018.

The gender pay gap is a reputational risk you cannot afford to ignore, as well demonstrated by some high-profile casualties over the past year.

Most recently, the FT has exposed sixteen companies which appear to have intentionally submitted inaccurate data. At least one company, Hugo Boss, changed its official submission after the FT pointed out that its results were unusual and asked for an explanation. A reputational blunder much more damaging than publishing the accurate figures in the first place, no matter how bad they may be.  

As we approach the deadline of 4 April 2018, the media will increasingly scrutinise employers seeking to fly under the radar or misrepresent their data. Moreover, gender pay poses a significant risk to employer brand and may lead to recruitment and retention issues.

Women should rightly hold their employer to account. Jayne-Anne Gadhia, chief executive of Virgin Money and author of the Women in Finance Charter, has encouraged women to vote with their feet: “What I’m starting to say to women now is, check whether or not your organisation has signed up. If it hasn’t signed up, find out why – and if you don’t like the answer, get out now and join a firm that has.”

Gender pay cannot be isolated as an HR issue, it must be seen as a business priority.

If your gender pay gap is significant, the worst thing you can do is nothing. Instead, consider taking the opportunity to establish a plan to improve the problem, then clearly and consistently communicate it to your employees and external stakeholders.

To help you tackle gender pay reporting as the deadline rapidly approaches, here are ten recommendations to kick-start your planning for 2018:

  1. Be transparent

    First and foremost, it is vital to present your gender pay figures clearly and transparently. Any attempt to be evasive or misleading will do much more harm than good, as well demonstrated by the FT’s investigation.

  2. Provide context

    If your gender pay figure is bad, you probably aren’t alone. While this should not invite complacency, it will help to contextualise your figures amongst your peers and the wider industry.

  3. Understand the cause

    Identify which factors have specifically contributed to your gender pay gap. Examples can vary widely from specialist skills and financial contribution to the business, which may be justifiable but will require explanation, to areas that will need addressing, such as unconscious bias or a weak return to work programme after maternity leave.

  4. Establish a plan

    It is not enough to simply explain why your gender pay gap exists e.g. “The majority of our senior leaders are men” (herein lies the problem). You must establish a plan to improve gender equality across your organisation. This could include a variety of measures, such as introducing anonymous job applications, signing the Women in Finance Charter or launching mentoring programmes to empower women to get into leadership positions.
  5. Create a narrative

    You have an opportunity to include a supporting narrative alongside your gender pay data. It is strongly advisable to create your own narrative, rather than allowing the media to articulate it for you. Crucially, point to contributions you have already made to tackle gender equality, as well as a commitment to further improve it. 
  6. Identify a spokesperson

    You are required to nominate a director who will be responsible for approving the gender pay calculations in a written statement. Take this opportunity to establish a prominent spokesperson on gender pay, and potentially wider diversity and inclusion issues within your organisation.

  7. Evaluate your stakeholders

    Having a problematic gender pay gap could present issues with a wide variety of stakeholders. The priority should be your people. But also consider other interested parties beyond the media. Customers, shareholders, suppliers and partners may all have a strong opinion, and communications must be tailored for each audience.

  8. Build a compelling EVP

    While negative media coverage will inflict pain in the short-term, lasting damage will be to your employer brand. Mitigate this by building a compelling employee value proposition. Could you strengthen your return to work programme for women on maternity leave? Or introduce flexible working?

  9. Develop a pipeline of female talent

    Gender pay reporting is an opportunity to profile wider gender initiatives and nurture female talent, such as partnerships with local schools and colleges to provide work experience for young women.

  10. Address wider diversity and inclusion issues

    The most progressive employers will see this as an opportunity to address wider diversity issues in the workplace. Gender pay reporting could be the catalyst to unite your whole organisation behind a shared goal of improving workplace equality.

If you would like to hear more about how we can help you with your company’s gender pay reporting, get in touch with us at:

This article is part of our Winter 2017 newsletter.