Gender pay gap reporting requirements - be aware

A bit off our usual area but as it will affect many operators within the leisure and licensed sector we are highlighting this new requirement.

By 4 April 2018 all employers with 250 employees or more must publish a gender pay gap report on their website, as soon to be required by the Equality Act 2010 (Gender Pay Gap Information) Regulations 2017, which are expected shortly to receive parliamentary approval.

The Regulations for the private and voluntary sectors cover any employer with 250 or more “relevant” employees in England, Wales and Scotland (but not Northern Ireland) on 5 April 2017 – and on the same date each year after that.  The Regulations apply the same definition of employee as the Equality Act 2010. This is a broad definition which includes zero hours’ workers, apprentices and some self-employed people.  Agency workers will be included in any reporting by the agency with which they have a contract of employment.

Employers are required to publish six metrics:

• The difference between the mean hourly rate of pay of male full-pay relevant employees and that of female full-pay relevant employees ( ‘the mean gender pay gap’);
• The difference between the median hourly rate of pay of male full-pay relevant employees and that of female full-pay relevant employees (‘the median gender pay gap’);
• The difference between the mean bonus pay paid to male relevant employees and that of female relevant employees (‘the mean gender bonus gap’);
• The difference between the median bonus pay paid to male relevant employees and that of female relevant employees (‘the median gender bonus gap’)
• The proportions of male and female relevant employees paid bonus pay (‘the proportions of men and women getting a bonus’); and
• The proportions of male and female relevant employees in the lower, lower middle, upper middle and upper quartile pay band (‘the proportion of men and women in each of four pay quartiles’).

Calculations for the pay gap metrics are to be based on a single pay period around the “snapshot date” of 5 April, while bonus gap metrics cover the whole year to April 2017.

ACAS has produced draft guidance which can be found here: http://www.acas.org.uk/media/pdf/l/6/Gender_Pay_Reporting_GUIDE.pdf

Their simplified factsheet can be found here: http://www.acas.org.uk/media/pdf/5/1/Gender_Pay_Reporting_OBLIGATIONS.pdf

If you employ more than 250, you need to be alert to this coming requirement.