Equal Pay Audit
For 2023 we have undertaken our equal pay audit following the approach suggested by the Equality and Human Rights Commission (EHRC) and their guidance for large organisations with over 50 employees.
Equal Pay is separate from the Gender Pay Gap and ensures that men and women in the same employment performing equal work must receive equal pay, unless any difference in pay can be justified.
The three steps of an Equal Pay Audit are to:
- Identify any differences between men and women doing equal work.
- Investigate the causes of any difference in pay between men and women doing equal work.
- Eliminate instances of unequal pay that cannot be justified.
This audit demonstrates our commitment as an employer to remove unfair pay practices.
The EHRC explains that gaps are to be expected when performing an audit, however this does not necessarily mean that pay discrimination has occurred or is deliberate. It is important to investigate these gaps to determine whether they can be justified and ensure that appropriate action is taken as a result.
1. Identification of any differences between men and women doing equal work
We have determined equal work using Mercer’s analytical job evaluation process. All our roles have been assessed using this process, which allows us to accurately identify job roles that are of equivalent size and scope. Combining this with the pay data used for the Gender Pay Gap analysis provides the basis for an organisation-wide investigation of pay differences by gender.
The EHRC recommend that “as a general rule, differences of 5% or more, or any recurring differences of 3% or more merit further investigation”.
Our audit identified no recurring differences of 3% for like work, and a small number of groups with a gap of 5% or more that warranted further investigation. The population with a 5%+ gap consisted of nine groups covering a total of 25 colleagues, or 2.3% of the total population. Note that we found no significant gap in our high-volume client-facing roles.
Our analysis found that the gap is often created by a single outlier in each group, and a third of these groups had a gap favouring women, and two thirds of the group had a gap favouring men.
2. Investigation of the causes of any difference in pay between men and women doing equal work
For the nine identified colleague groups, we have worked with local management to review the causes of pay gaps on an individual basis.
Our investigation found that most gaps are justifiable and are typically based on an individual’s experience, competence and performance as well as personal choices to reduce pay through salary exchange schemes.
3. Eliminate instances of unequal pay that cannot be justified
The small number of remaining gaps can be explained, although not justified, by compounding pay factors such as inflation-based pay review uplifts for those employed for longer periods. In these cases, we have implemented targeted plans to correct these pay gaps over time.
These outcomes give us confidence that we do not have a widespread equal pay issue, and that our regular pay management processes, and how they are being applied, does not discriminate.
As with the Gender Pay Gap, there is an expected natural fluctuation in these gaps over time as the colleague population changes. We will continue to monitor and identify any gaps in equal pay and perform the necessary steps to close any gaps that arise.