After carrying out an equal pay audit or review, the specific actions you need to take to address any issues will depend on the nature and extent of any unequal pay you’ve identified and its causes.
One of the most important steps is to formulate an action plan. A key step in the action plan is to produce an equal pay policy.
The equal pay policy should commit your organisation to providing equal pay and include specific objectives, clear accountabilities and defined procedures for regular monitoring and review.
It should be a distinct and explicit equal pay policy, 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. For example, your objectives and actions might demonstrate your commitment to:
- employees to provide equal pay for equal work ( including basic pay, non-discretionary bonuses, and other contractual benefits)
- discuss and agree the equal pay policy with trade unions
- undertake 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
- set up an equal pay group which will assess findings of the equal pay review and take action where necessary
- communicate the results of your equal pay audit to staff and further afield.
- monitor starting salaries for new staff, and
- provide 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.
Monitor and review
Developing an equal pay policy is only one step on the path towards equal pay. The policy must be rigorously implemented and constantly monitored and reviewed to make sure it remains effective.
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: 19 Feb 2019