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We applaud the aim of the Government to try to “tackle the complex drivers of the pay gap” and produce proposals which will be “Proportionate and effective” (quotes from Nicky Morgan in the Foreword to the current Consultation). However, we regret that the outcome so far – the draft Regulations which are the subject of this Consultation – appears to us to be disappointingly simplistic.
Whilst we understand that this is only part of the story, any requirement to report should be an effective tool to help achieve the overall objectives which should be to identify the nature of any gender pay gap(s) within the relevant business and, more importantly, take steps to try to eliminate it/them.
We know that there are gender pay gaps and that it would be useful to measure them. Reporting the measuring exercise could help the aim of tackling the underlying causes of the gaps. The objective of the reporting of comparative gender pay should be primarily to make employers aware of any inconsistency of pay arrangements and outcomes within their business based on gender. This knowledge can then be used by the employer, in conjunction with many other factors, in reducing such inconsistencies and ensuring that they are compliant with any relevant Equal Pay and anti-discrimination legislation.
This response is prepared jointly by : THP HR Consultants (please contact John Nichols on 07860 495734 or email@example.com) in association with Tom Flanagan Consulting (https://uk.linkedin.com/in/tom-flanagan-93b6933a)