roles
Employers may wish to consider providing contextual information alongside gender pay information to
clear up any misleading impression and to avoid any negative publicity. A pay gap does not necessarily
signify unlawful discrimination. This will be particularly important to keep up a positive image compared
with competitors. Although providing narrative may be helpful in some instances, if it becomes the trend
to provide lengthy narrative, this may have a detrimental effect on actually decreasing the gender pay gap
(because it will become the norm to rationalise any gender pay gap).
Employers may also wish to undertake an internal equal pay audit in advance of being required to publish
the results in the public domain.
If discrepancies between the pay of men and women come to light, and
equal pay claims are threatened by employees, a business may be influenced to settle equal pay claims to
avoid any negative publicity. If any new complaints or grievances come to light in respect of pay
discrepancies between men and women, an employer’s human resources department and management
should work together to provide a consistent approach to such complaints or claims. Employers may also
wish to provide training to management about the requirements under these regulations and to update
policies where necessary.
CONTACTS
If you have any questions or would like more information on the issues discussed in this LawFlash, please
contact any of the following Morgan Lewis lawyers:
London
Matthew Howse
Pulina Whitaker
[1] View the government’s announcement here.
[2] View the government’s response here.
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