Your audit is not just a data collection exercise. Alert senior management to the possible outcomes of the audit and secure their commitment to an equal pay action plan. Make them aware that the audit needs to be built on a commitment to possible changes in pay.
Key messages include:
- Expect some pay gaps and anticipate step five
- Your equal pay audit may not reveal all your individual equal pay vulnerabilities
Setting expectations and dealing with outcomes
Many employers genuinely believe that they are providing equal pay. They embark on a review with an expectation that no inequalities will emerge. It is important to recognise that an equal pay audit is not simply a data collection exercise. It entails a commitment to action if unjustified pay gaps are found.
Early in the process you will need to set realistic expectations about possible outcomes. This may include:
Expect some pay gaps
It is rare for employers to emerge from a properly conducted pay audit without some pay gaps or aspect of pay policy requiring change. That does not mean that pay discrimination has been deliberate. Pay gaps are likely to have been caused by the impact of historical factors, such as service. The gaps may be justified. Take one step at a time in the analysis and explanation of pay gaps and remain objective. More advice on analysing the causes of pay gaps is given at step four.
Alert senior management to the possible outcomes of the audit and secure their commitment to an equal pay action plan. Make them aware that it is not just a one-off data collection exercise but part of an ongoing process that includes anticipating the possibility of action under step five of the kit to close pay gaps.
An equal pay audit may not reveal all your individual equal pay vulnerabilities
The focus of an equal pay audit is on ‘systemic’ inequality in pay – identifying and resolving gaps in average pay between groups of men and women, between people from different ethnic groups and other protected groups. Its prime purpose is to explore whether pay policies or practices, past or current, have systematically disadvantaged any particular group.
In most organisations it would be unrealistic to compare the pay of, for example, every male employee with that of every female colleague performing equal work and to investigate every one of those gaps because of the sheer number of possible comparisons.
That limitation is all the more marked given the large number of permutations of possible comparison between groups of employees from different ethnic groups. Some powerful bespoke equal pay audit software has the facility to analyse relative pay between individuals for organisations particularly interested in this level of risk analysis.
The focus on systemic inequality in an equal pay audit does not preclude some consideration of individual pay, whether as part of a spot-check/sampling process, as part of the process of considering known ‘sore thumb’ vulnerabilities, or as part of the data analysis process - step 3 of your audit.