Last week, the NHF published its final version of its new Code of Governance and made some important changes from the previous draft that will impact on those housing associations looking to adopt it.
The requirements largely mirror those being imposed on the private sector, reported in our briefing in October 2016: Gender Pay Reporting is coming – are you ready?. However, they are being introduced as part of the existing public sector equality duty rather than as a stand-alone requirement, but will mean little difference in practice.
The duty will apply to specific public authorities listed in Schedule 2 of the Regulations (which includes the governing bodies of educational establishments, local authorities and regulators). As in the private sector, the duty will only apply where there are 250 or more employees at that establishment.
The main difference to the private-sector duty is that the public sector will have a different ‘snapshot date’ for reporting of 31 March 2017. Otherwise, the obligations and calculations are the same.
What should you do now?
Whilst the private and public sector regulations required parliamentary approval, we expect them to be implemented with very little change. We are urging all employers in the public and private sectors to take steps now to understand in more detail how the Gender Pay Regulations will affect them. Our top tips are to:
- Carry out in-depth assessments of your workforce to establish who may be captured as an “employee” and what will be regarded as “pay” in light of the revised Regulations;
- Carry out a pay audit to identify what your likely gender pay gap will be and the reasons for this;
- Consider what information you will want to add to any gender pay report, to set your figures in context, and explain an unusual pay gap;
- Start to plan a strategy to address any gender pay gap;
- Consider your communication strategy, both internally and externally, for when you publish your gender pay gap figure; and
- If possible, benchmark your gender pay gap within your industry or against comparable public bodies to identify whether your figures are likely to be an issue.
For further information
For further information about what you can do now to prepare for gender pay reporting, please contact Kate Watkins.
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