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Pay Gaps #24 – Briefing Note for Parliament’s debate on Ethnicity Pay Gaps

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The UK Parliament is about to debate whether or not ethnicity pay gap reporting (EPGR) by UK employers should be made mandatory.  The debate will start at 4.30pm on Monday 20th September 2021 and is a result of an e-petition reaching the threshold to require a parliamentary debate.  To assist MPs, journalists, campaigners and anyone else interested in this debate, I have written a briefing note which lists 9 key points that need to be addressed during the debate.

Update 20th September – The Parliament TV link is here and my live-tweet thread is here.

You can download my 8 page briefing note using this link.

Nigel Marriott’s Briefing Note re Ethnicity Pay Gap Reporting 12th September 2021

You are free to quote anything from this or indeed from any of my blogs but I would appreciate being acknowledged as the source.  I prefer to be described as Nigel Marriott, Independent Statistician but Nigel Marriott, Chartered Statistician is also acceptable.

There are 3 sections (scroll down for full list of contents) in the note –

  1. (3 pages) 9 key points that must be borne in mind when considering ethnicity pay gap reporting legislation
  2. (1 page) 6 key blog posts of mine that explain my thinking on EPGR in more detail
  3. (2 pages) A summary of my background and experience

I would urge anyone interested in this debate to take note of the many complex issues that have to be addressed before any EPGR legislation can be enacted.  Employers already struggle with gender pay gap reporting (GPGR) and I am currently auditing a random sample of 440 employers gender pay gap reports to measure how well or badly they are doing GPGR.  Initial results are discouraging (final results will only be available to subscribers of my newsletter) and I expect these to be at least 10 times worse with EPGR.  There is no magic bullet to overcome the issues I have talked about since June 2019 when I gave evidence to the Treasury Select Committee.  Parliament will be faced with a choice between a voluntary system where some motivated employers do a semi-decent job and a mandatory system where the vast majority of employers will not have a clue what to do and with many not having any usable data to analyse in the first place.

I’ve see many campaigns for EPGR to be introduced and I have always supported the principle of EPGR.  However, I see no-one apart from myself spending time looking in detail as to how EPGR can be done.  My briefing note lists the issues that need to be debated with respect to the How.  The response I have had at times when I raise these issues has echoed the surreal experience of Anderson in the quite brilliant YouTube clip “The Expert“.  I reproduce the narrative from 4 minutes 40 seconds in which typifies the kind of response I get at times.

  • Sales Manager – “So what’s the problem here?”
  • Anderson – “Geometry”
  • Sales Manager – “Ignore it!”

 

Briefing Note – List of Contents

Section 1 – 9 Key Points to consider with Ethnicity Pay Gap Reporting (EPGR)
  1. EPGR legislation cannot replicate current GPGR (Gender Pay Gap Reporting) legislation
  2. There has been no public debate on the HOW of EPGR
  3. If EPGR is mandated, the current GPGR legislation will need to be amended as well
  4. I endorse recommendation 9 of the Commission for Racial & Ethnic Disparities (CRED) report
  5. Employers should be free to use ethnic categories that are meaningful to their employees
  6. Employees must be free to not declare their ethnicity
  7. EPGR legislation must state a minimum category size for data to be reported
  8. Legislation requiring mandatory EPGR should only apply to employers with 1,000+ employees
  9. Is voluntary EPGR by some motivated employers better than mandatory EPGR with many issues?
Section 2 – List of blog posts I have written about Ethnicity Pay Gap Reporting in chronological order
  1. June 2019 – My evidence to the Treasury Select Committee on effectiveness of Pay Gap Reporting
  2. July 2019 – Should the UK introduce Ethnicity Pay Gap Reporting?
  3. February 2020 – How could the UK introduce Ethnicity Pay Gap Reporting?
  4. November 2020 – Why Employers should report their Ethnicity Pay Fingerprints.
  5. June 2021 – My 7+5 recommendations for amending pay gap legislation
  6. August 2021 – How many ethnic categories should an employer report?
Section 3 – My background & experience
  1. How I became interested in pay gap reporting
  2. My Career
  3. My Involvement with the Royal Statistical Society
  4. My Academic Qualifications
  5. My Social Media links (Professional only)

 

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— Need help with understanding your pay gap? —

I offer the following services.  Please click on the headings for more details.

  1. Analysis – I can dig deep into your data to identify the key drivers of your pay gaps.  I can build a model using a large number of variables such as pay band, seniority, job function, location, etc and use this to identify the priority areas for closing your gaps.
  2. Training – I run training courses in basic statistics which are designed for non-statisticians such as people working in HR.  The courses will show you how to perform the relevant calculations in Microsoft Excel, how to interpret what they mean for you and how to incorporate these in an action plan to close your gaps.
  3. Expert Witness – Has your gender pay gap data uncovered an issue resulting in legal action?  Need an expert independent statistician who can testify whether the data supports or contradicts a claim of discrimination?  I have experience of acting as an expert witness for either plaintiff or defendant and I know how to testify and explain complex data in simple language that can be easily understood by non-statisticians.

If you would like to have a no-obligation discussion about how I can help you, please do contact me.