With mandatory gender pay gap reporting becoming a legal requirement for some companies this month, effective reporting is essential. Doone O'Doherty outlines her five-step guide to getting it right
Irish companies employing 250 people or more were required to publish their first gender pay gap report online by 1 December 2022, but not all have met the deadline. For those lagging behind, there are potential consequences.
Guidance issued by the Department of Children, Equality, Disability, Integration and Youth, notes that: “The Gender Pay Gap Information Act 2021 provides the Irish Human Rights and Equality Commission with the power to make an application to the Circuit Court or to the High Court for the granting of an order requiring the employer concerned to comply with the Regulations”.
The 2021 Act also provides that an employee may refer their employer to the Director General of the Workplace Relations Commission for failure to comply with regulations.
It is therefore crucial that any company employing 250 people or more, which has yet to publish its gender pay gap, take immediate steps to do so. Here are the five steps I recommend:
1. Complete your calculations
The Gender Pay Gap Information Act 2021 outlines 11 specific data points that must be included in reports. Companies should ensure that:
- they understand what is required, such as who is included in the count, the snapshot timeframe, and what counts as ‘ordinary pay’ and ‘remuneration’, etc.;
- they have gathered all relevant data needed for the calculations; and
- calculations are complete.
Once this is has been done, the focus should shift to conducting any additional analysis needed to contextualise the numbers in the report.
2. Document your approach
Your calculations will need to be re-run annually, and your 2022 gender pay gap number will be the baseline against which annual progress will be measured. Ensure your approach is well documented so that your organisation can compare like-for-like each year.
As some aspects of the legislation are unclear, a judgement call may be needed. In this context, documenting the rationale will be important.
3. Finalise your report
In addition to the reporting of certain data points, the legislation requires that companies:
- explain the reason for any gender pay gap; and
- ·outline measures that have been taken or proposed to close the gap.
Ensure that any reasons given for the gap are evidence-based. Do the numbers reported support the reasons for a gap, for example? Are actions proposed to close the gender pay gap in your organisation realistically implementable?
In finalising your report, consider the following:
- the branding support needed to ensure that the report aligns with other publications produced by your organisation;
- who in the organisation will carry out a final review;
- who will provide the final sign-off; and
- who will be responsible for uploading the report to your website.
4. Lock down your communications strategy
With a sensitive and technical topic like gender pay gap reporting, effective communication is essential. When considering your communication strategy, make sure that:
- your marketing and public relations teams are prepared to execute the communication strategy;
- all senior stakeholders are fully briefed on the key messages for both internal and external audiences; and
- you have considered whether you should nominate a team member responsible for responding to media queries and social media comments.
5. Start to prepare for year two
There will be a very short window between reporting now and the next snapshot date in June 2023. To ensure that you can demonstrate progress in closing your gender pay gap, you must drive ongoing Diversity, Equity and Inclusion (DE&I) plans and consider whether new initiatives may be required.
The steps companies take now when publishing their reports will largely determine how their gender pay gap rating will be received and understood, both internally and externally.
My advice is that employers prepare their completion checklist without delay—and check it twice.
Doone O'Doherty is Partner of People & Organisation in PwC
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