As a consultancy we do not take any position about "should" or "should not".  That is for the pressure and campaign groups.  Our role is to help client organisations achieve their pay policy objectives.  These may range from a high profile, positive campaign to putting responsible modest effort into ensuring there are no avoidable and unknown equal pay problems.  Both may be sensible strategies - it all depends on the organisation.

The prudent minimum - legal compliance - will certainly involve a careful audit of what is happening within the pay system - the facts - and depending on the data, consideration of addressing remuneration policies and practices.  Monitoring pay (and other benefits) by gender is essential, both to understand the dynamics of the remuneration system and to have any reasonable chance of defending a claim. 

A comprehensive analysis is based on a model (and sequence) of:

• What

• Where

• Why

• Actions

• Monitoring

Establishing the facts.  For a large organisation this is seldom simple.  Data required certainly includes:

• Grade
• Base pay
• Variable pay
• Benefits value
• Gender
• Length of service
• Time in grade
• Age

Where the remuneration system includes merit related pay reviews, appraisal ratings can be very useful. 

If accessible, analysis of appointment salaries (external hires, promotions and regradings) is important, as is the gender of jobholders in roles put forward for re-evaluation.

Given the effort that has to be put into establishing facts, it is usually sensible to review not just gender differences.  If the data are available then ethnicity and disability are important and anyway very useful in interrogating equal pay differences.  It is not unusual to find that differences between male and female ethnic minority employees are greater than the comparable differences for white populations.

In short, we apply sophisticated statistical analysis to all relevant available data.  Data can usually be exported to us from the corporate HR Information System, although quite frequently we are dependent on several separate internal sources that then have to be integrated. 

In all probability any review will show some significant differences between remuneration men and women.  An employer can do something about this with information about “where” as well as "what".  This we establish statistically. 

“Where” means where in the remuneration processes, where in terms of location or function, and where structurally.  The structural factor (different gender profiles by grade or function) can give rise to “headline” differences in average pay but is not necessarily a statutory issue.  It still needs quantifying as part of the total picture, and most employers will want to factually understand "glass ceilings" and other structural issues.

Our analysis identifies the extent to which any differences can be attributed to (examples) appointment salaries, merit based reviews and bonuses, or differential incidence of regrading.

What are the causes of pay differences?  Having established and quantified differences, and identified where they are occurring (both location and where in the reward system) we can investigate the associated policies and practices.  There can be surprising results.

Example: A major plc with merit related pay reviews.  Mean appraisal rating for men and women showed no significant difference.  However, statistical analysis of appraisal distribution showed that women were significantly less likely to receive either a "poor" or "very good" appraisal.  The performance review matrix was skewed to "high-performers”.  The result was that female staff received, on average, lower pay reviews.

We identify for clients the policies and practices that need changing in order to achieve equal pay objectives.  These include detailed costing and impact assessment.

It is essential that a review is not a one-off exercise.  We can establish for a client appropriate measures for tracking equal pay factors, using the results of the initial programme as the reference point.

A professional and comprehensive review takes time and skilled resource.  Even the largest organisations seldom have available the necessary technical knowledge – salary administration, job evaluation, progression systems, statistical analysis, data processing and legal framework.