What happens next in your equal pay audit depends on whether or not you found any pay gaps related to protected groups for which there was no satisfactory explanation and justification. If you found any such gaps you should:
The specific actions you need to take will depend on the nature and extent of the pay gaps you have identified and their causes. As you worked through step 4 identifying the causes of the pay gaps, the actions required will probably have become clear - though not necessarily easy to implement. Where possible, involve the trade unions in formulating the plan.
At a headline level your action plan should include arrangements to:
If your audit finds pay gaps related to gender, ethnicity, disability or working pattern, for which there is no justification, you should plan to provide equal pay for current and future employees as soon as is practicable. If the pay discrimination that you have found is direct pay discrimination against women, then you must put it right immediately. Read more information on time scales.
Once your equal pay audit identifies the causes of unequal pay and shows that those causes are not justified, you should change any current pay policies and practices that have, or continue to, contribute to unequal pay.
Examples of pay policies and practices which organisations have needed to change following equal pay audits include starting salaries, performance management systems, promotion calculations, market supplements, pay protection and eligibility for bonuses and allowances.
Publish an equal pay policy that commits your organisation to providing equal pay, with clear accountabilities, regular monitoring and adequate resources for equal pay audits.
It should be an explicit pay policy, rather than something vague hidden away in a more general equality and diversity policy.
An equal pay audit is not a one-off event. In order to ensure your pay system remains free from bias, you will need to continue to review and monitor pay outcomes by protected groups. Annual monitoring is recommended e.g. of performance pay and other pay increases, and ongoing review of the impact of new pay policies as they are implemented. Advice on what and how to monitor can be found in other parts of the kit including:
Advice on good equal pay practice can be found in the equal pay in practice guidance series.
Public authorities are required to conduct equality impact assessments of proposed new pay policies and structures. For more details on this, see equality impact assessments.
One beneficial by-product of doing an audit is that it may have highlighted other equality issues, such as under-representation or job segregation, in your organisation. As a result, you may wish to examine other employment practices identified during the audit. These might include recruitment processes, segregation of protected groups by job type and seniority, approaches to training and development and succession planning.
For an example see: University of Sunderland Equality and Diversity
You may also decide to include equality questions in employee opinion surveys to assess progress and to identify priorities.
See also Step 5 - additional information
Please send any feedback or enquiries to equalpayfeedback@equalityhumanrights.com.