A key step in developing an Equal Pay action plan is to produce an equal pay policy, which should be distinct and explicit, not an add-on to a more general equality and diversity policy.
A good equal pay policy will typically cover the following areas:
Begin with a written statement that clearly sets out your organisation’s commitment to tackling sex discrimination and providing equal pay.
Provide clear and readily understandable definitions of all terms used in your equal pay policy, and their context with regard to your organisation’s legal obligations under the Equality Act 2010 or other legislation.
Typical terms may include:
- equal work, and
Objectives or actions
Describe precisely how you intend to provide and maintain equal pay in your organisation.
Actions and commitments that employers who have Equal Pay action plans include:
- a commitment to provide equal pay for equal work ( including basic pay, non-discretionary bonuses, and other contractual benefits)
- discussing and agreeing their equal pay policy with trade unions
- undertaking regular equal pay reviews or audits for all employees in line with the Code of Practice and repeat them at regular intervals and use the details to address any instances of discrimination in pay
- setting up an equal pay group which will assess findings of the equal pay review and take action where necessary
- plans for communicating the results of your equal pay audit to staff and further afield.
- monitoring starting salaries for new staff
- providing training and guidance for those involved in determining pay
Set out how you will respond to any concerns and complaints about possible breaches of the equal pay policy, along with details of any grievance procedures that employees should follow.
Include a statement of your commitment to regularly review the policy and assess your progress in delivering the action plan and explain how you will share information from these reviews with other stakeholders.
Identify all those involved in the implementation of your equal pay policy and what their responsibilities are.
While every effort has been made to ensure that this advice is accurate and up to date, it does not guarantee that you could successfully defend an equal pay claim. Only the courts or tribunals can give authoritative interpretations of the law.
Last updated: 03 Sep 2020