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Equality and Human Rights Commission (EHRC) : More employers should publish gender pay gap narratives and action plans

07 January 2019

In December, EHRC published a report on the first round of gender pay gap reporting, focusing on explanatory narratives and action plans.

EHRC's gender pay gap report - what did it tell us?

The EHRC analysed the pay gap reports of 440 employers and noted that only around half of these included a narrative to explain the reasons or context behind the figures. Furthermore, only one in five of these employers had produced an action plan setting out steps to narrow their gender pay gap and only one in ten had set targets for improvement which could measure progress year on year.

The report highlights the opportunity for employers in publishing a narrative and action plan along with their statistics. For example, publicly demonstrating their commitment to addressing the gap can improve an organisation's recruitment and retention and help to build a reputation for being fair and progressive. A survey of employees working in firms which have published their gender pay gap data revealed that over 60% of women surveyed would be more likely to apply for a job with an employer with a lower pay gap and that over half would feel demotivated if they worked somewhere with a gender pay gap. The survey, undertaken for the EHRC, is available here.

Recommendations to employers

The EHRC report includes examples of good practice in addressing the gender pay gap and recommends the Government guidance in this area.

The National Council for Voluntary Organisations (NCVO) recommended last year that all voluntary organisations should consider publishing their gender pay gap statistics even if they have fewer than 250 employees and so are not required to report. The NCVO considers that publishing this data is "a way to reflect on any gender pay differences and to demonstrate a commitment to transparency and accountability".

How you can have your say

The Government is currently consulting on the possibility of bringing in mandatory ethnicity pay gap reporting. The consultation document and link to respond online are available here. The deadline for response is 11 January 2019.  We will report separately on Wrigleys' response to the consultation later this month.

If you would like to discuss any aspect of this article further, please contact Alacoque Marvin or any other member of the Employment team on 0113 244 6100.

You can also keep up to date by following Wrigleys Employment team on Twitter

The information in this article is necessarily of a general nature. Specific advice should be sought for specific situations. If you have any queries or need any legal advice please feel free to contact Wrigleys Solicitors.




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Alacoque Marvin


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