Two months ago, the Department for Business & Trade (DfB&T) in collaboration with the Equality Hub (EqHub) and Race Disparity Unit (RDU) published Ethnicity pay reporting: guidance for employers. This is “guidance for employers on how to measure, report on and address any ethnicity pay differences within their workforce” and fulfills Action 16 of the government’s Inclusive Britain action plan. I was asked to write the draft version of this guidance and I have to confess to being disappointed with the final version published. I will explain why I am disappointed and why I have decided to publish an edited version of my draft as well.
Is pay gap reporting about transparency or accountability? This was the main theme of the House of Lords debate on Ethnicity Pay Gap Reporting (EPGR) on 25th October 2021, unlike the Commons debate that preceded it in September. The 9 peers who spoke could be split between those who see EPGR as an exercise in employer transparency and those who see EPGR as an exercise in employer accountability and I consider this to be a fundamental question that has not yet been answered. In this article, I will discuss the implications of both answers to this question for any future EPGR legislation.
The UK Parliament debated Ethnicity Pay Gap Reporting (EPGR) on 20th September 2021 in Westminster Hall. Seven MPs spoke in the hour long debate and, as debates go, I thought it was actually quite good. There was cross party consensus on the merits of EPGR but I saw a divide between those who recognise EPGR is complex and requires trade offs and those who think the complexities of EPGR can be solved with government guidance.
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.
When I submitted my evidence to the Commission on Racial and Ethnic Disparities (CRED) in November 2020, I recommended that ethnicity pay gap reporting (EPGR) using the Big 5 ethnicities of White, Asian, Black, Mixed & Other be made mandatory. In the CRED report published in March 2021, recommendation 24 called for analysis of ethnicity to use the Office of National Statistics (ONS) 18+1 ethnicities as much as possible and it is my opinion this is one of the reasons why CRED stopped short of recommending mandatory EPGR in recommendation 9. In June 2021, I published 7 + 5 recommendations for improving gender pay gap reporting (GPGR) and I made it clear that all 12 of my recommendations would also apply to any EPGR system introduced by the government. However, I stated my 2nd recommendation on number of categories to be reported needed more details before it could be applied to EPGR and this article will fill in those details whilst also recording my response to recommendations 9, 10, 23 & 24 of the CRED report.
You have just started work for a new employer and with you joining, the company now has 25 employees. All are white including you. Would you raise your eyebrows at that?