In the last briefing we looked at what constituted
a Pay Systems Review.
The only way in which an employer can determine
this is to carry out an equal pay audit. This will reveal the
nature and extent of any gender pay inequalities. Action can then
be planned and implemented to remedy any inequalities.
This briefing moves to the next step of the process
of determining whether inequalities exist in pay systems.
The Equal Pay Taskforce – an independent body made
up of senior representatives from industry, trade unions, the
civil service and the public sector, as well as experts in pay
equality and gender issues – was established by the Equal Opportunities
Commission. It spent over a year examining the current position
on equal pay and made 5 clear recommendations about how the matter
should be taken forward if equal pay between men and women was
to be eliminated in 8 years.
A key recommendation was the need for the current
Equal Pay legislation to be amended to require employers to carry
out regular equal pay audits. Current legislation only allows
for a voluntary pay review. As many employees are reluctant at
present to commit themselves to such reviews the onus is on trade
unions to press for them to take place. They proposed a two stage
pay review process.
If an employer is persuaded to undertake an audit
there are two stages which need to be followed.
Stage One is a Pay System Equality Check. The purpose
of the Stage One Review is to provide a simple, speedy check to
enable employers to begin to establish whether they have a gender
pay gap. It is essential that employers complete this Stage One
Review unless they can show they have already completed a full
systems pay review in line with the EOC's Code of Practice. This
Code of Practice is currently being revised to bring it up-to-date
and provide information in plain English. Further info from the
Overleaf is a suggested model for a Stage One Review.
For those employers who have identified a gender
pay gap as part of a Stage One Review a more detailed Stage Two
Equal Pay Review should follow. Details of Stage Two will appear
in a future briefing.
Pay System Equality Check
Answer the following questions:
- Does your organisation have a stated policy on equal pay4?
- Has the equal pay policy been communicated to employees
and recognised trade unions?
- Has responsibility for the implementation of the policy
been clearly assigned?
- Have you carried out a pay systems review to establish whether
you have a gender pay gap, in line with the EOC's Code of
- Does your organisation use a single job evaluation5
system covering all employees to determine who is performing
If you answer 'yes' to all the questions you have
taken the key steps to begin to address the question of equal
pay as an employer. Continue regularly to review all aspects of
your pay systems for inequalities.
'No' answers to questions 4 and 5 indicate that
you cannot be confident you are an equal pay employer. The equal
pay review below will help you to determine whether you have a
gender pay gap.
4 An example can be found in the EOC
Code of Practice on Equal Pay
5A job evaluation scheme must be analytical,
using factors such as effort, skill and decision, and free of
sex bias in design and operation to meet the requirements of equal
Equal Opportunities Commission
0141 248 5833
Scottish Executive Equality Unit
0131 244 0123
Scottish Low Pay Unit
0141 221 4491
Scottish Trades Union Congress
0141 337 8100
Fair Play Scotland
0141 248 5833