GENDER PAY REPORTING AN INTERNATIONAL …/media/files/insights/events/...legal duty to assess and/...

GENDER PAY REPORTING AN INTERNATIONAL SURVEY (SEPTEMBER 2018)

CONTENTS

AUSTRALIA 04

FINLAND 23

MEXICO 40

SPAIN 49

AUSTRIA 07

FRANCE 26

NETHERLANDS 41

SWEDEN 50

BELGIUM 09

GERMANY 29

NORWAY 42

UAE 52

CANADA 11

HONG KONG 31

POLAND 46PHILIPPINES 44

UK 53

CHINA 20

ITALY 36IRELAND 34

INDIA 32

ROMANIA 47

US 56

DENMARK 21

JAPAN 39

RUSSIA 48

GLOBALOVERVIEW 03

02 | Gender Pay Reporting: An International Survey (September 2018)

Gender pay reporting: A summary across 26 countries

Australia Austria Belgium Canada2 China Denmark Finland France Germany Hong Kong India Ireland Italy Japan Mexico Netherlands Norway Philippines Poland Romania Russia Spain Sweden UAE UK US3

1 In many countries, the duty will only apply where a certain employee threshold is met. In some countries, there may be different/additional duties on government or state sector companies 2 Certain provinces in Canada only 3 Proposals to implement a duty to report at a federal level were finalized in September 2016 but have been swayed indefinitely by the current administration

Country Is there a duty on companies to report on gender pay difference?1

Is the company required to make the report available internally to

employees and/or reps?

Is the report required to be or likely to be published externally

or made public?

www.dlapiper.com | 03

AUSTRALIA

Are employers under a legal duty to assess and/or report on gender pay differences?

Yes, private organisations with 100 or more employees must submit an annual report to the Workplace Gender Equality Agency (WGEA) that includes details of aggregated average base salary and total remuneration of male vs. female employees.

Which employers are covered?

Private sector employers with 100 or more employees are covered by the reporting requirements and private sector employers with 500 or more employees have an additional obligation to meet certain minimum standards for gender equality.

What are the key assessment/reporting obligations?

Annual workplace profile and reporting questionnaire to be produced, signed by the CEO and which may be published on the WGEA website. Report to show information including:

■ aggregated average base salary and total remuneration of male vs. female employees in various occupational categories;

■ gender composition of the workforce and whether any policies are in place to support gender equality;

■ gender composition of the board of directors and whether any targets are in place for representation of women on the board;

■ details of gender pay equity objectives and policies (if any);

■ whether any gender remuneration gap analysis has been undertaken;

■ availability of flexible working arrangements;

■ consultation with employees on issues concerning gender equality in the workplace;

■ sex based harassment and discrimination policies; and

■ the number of new appointments, promotions and resignations during the reporting period by gender, employment status and manager/non-manager categories.

No data on actual individual pay rates is required to be disclosed to the WGEA: all amounts are aggregated and individual data de-identified. Remuneration and pay data provided to WGEA by employers is confidential. Employer-specific remuneration data will only be disclosed publicly by WGEA in aggregated form e.g. on an industry-wide basis.


Does the duty apply only to employee pay or also to the pay of other workers?

Employees only.

Does the report have to be provided to employees and/or employee reps?

The employer must inform employees (and shareholders) that it has lodged the report with the WGEA and the way in which it may be accessed (whether electronic or otherwise). The employer must also take all reasonable steps to inform each employee organisation (e.g. a union) that has members who are employees of the employer, that the employer has lodged the report.

Does the report have to be published and if so where?

The report may be published by the WGEA on its website or in whole or in part in a report to the Minister, in which case it would then be tabled before Parliament. Remuneration and pay data provided to WGEA by employers is confidential. Employer-specific remuneration data will only be disclosed publicly by WGEA in aggregated form e.g. on an industry-wide basis.

If a pay gap is identified is there any duty to take steps to close the gap?

No

What is/are the sanction/s for non-compliance (if any)

No legal sanctions/fines, but employers who do not comply could be named and shamed by the WGEA in a report to the Minister or by some other means (e.g. on the WGEA’s website). The employer may also be precluded from tendering for Commonwealth and some State contracts, or from receiving Commonwealth grants or other financial assistance.

What has the impact been of any pay reporting measures introduced in your jurisdiction?

The introduction of the WGEA Act 2012 brought about significant changes to the WGEA and introduced more onerous reporting requirements than had previously existed. The reporting requirements also become more onerous in the reporting year 1 April 2015 to 31 March 2016.

The impact of the measures has been that many leading employers seek to be recognised as an Employer of Choice for Gender Equality by the WGEA. There is also a trend in Australia towards greater public scrutiny around under-representation of women in executive positions and on boards.

AUSTRALIA


Are employers encouraged to assess and/or report on gender pay differences? If yes, briefly summarise the steps that employers are encouraged to take.

Yes, the annual report includes questions around:

■ whether any gender remuneration gap analysis has been undertaken; and

■ whether the employer has any gender pay equity objectives and policies.

Are there any other relevant developments/measures in your jurisdiction relating to the gender pay gap?

The WGEA Employer of Choice for Gender Equality citation is designed to encourage commitment to achieving gender equality. Organisations can apply for a citation by applying online and answering additional questions and providing additional information and examples.

AUSTRALIA


AUSTRIA


Yes, since March 2011 there has been a duty for employers with more than 150 employees to prepare a report showing gender pay differences every two years.


Private employers with more than 150 employees.


The report has to be produced every two years and must contain the following information:

■ number of male and female employees and their positions in salary schemes according to collective bargaining agreements or internal salary schemes and their seniority (“Verwendungsgruppe” and “Verwendungsgruppenjahre”) and

■ average male vs. female salary

Total remuneration including benefits, payments in kind, special payments (Christmas and vacation pay) and other forms of payment must be included in the report.


Employees only.


The report must be provided to the works council. If there is no works council, the employees must be made aware of the report. The information must be provided on an anonymous basis.


If there is no works council, the employer must provide the report in such a way that the employees are aware of its existence (e.g. on an intranet site or notice board).


No


AUSTRIA


The works council or employees themselves may bring a claim within three years relating to the provision of the report at the Labour Court.

Employee representatives and employees themselves are obliged to keep the report confidential. If an employee breaches the duty of confidentiality, the employee can be fined (up to EUR 360).


N/A


N/A


A significant change to the Stock Corporation Act (AktG) and the Limited Liability Companies Act (GmbHG) will impact on gender equality. As of 1 January 2018, the boards of Stock Companies (AG) and Ltds (GmbH) are subject to a minimum quota requiring 30% of members to be female.

If the following requirements are fulfilled the appointment of new board members is limited to female candidates until the quota of 30% is satisfied (appointments of non-female members made before this quota is reached will be invalid):

■ The company must be listed or employ at least 1,000 employees;

■ The board must have at least 6 shareholder representatives;

■ The general woman/men quota of the workforce must be over 20%;

■ The staff and shareholders representatives of the board have to fulfil the quota separately.


BELGIUM


Yes – employers employing 50 employees or more need to draft an analysis report on the salary structures of employees every two years.

This analysis report should enable an assessment to be made as to whether the company has a gender neutral remuneration policy.


Private sector employers with 50 or more employees


Bi-annual analysis report to be produced on the salary structure of employees.

The analytical report should be drafted on the basis of the forms included in the Royal Decree of 25 April 2014. There is a form for technical operating units with at least 100 workers, and a, reduced, form for technical operating units with between 50 and 100 workers, but where a union delegation has been established.


The duty only applies to the pay of employees.


The report has to be communicated and discussed with the works council, or in absence of a works council, with the trade union delegation.


No


Once the analytical report has been drafted and communicated to the works council, it is up to the works council to decide whether or not it is appropriate to draft an action plan for ensuring a remuneration structure independent of gender. In companies who have to draft an analytical report but do not have a works council, this decision should be taken by the union delegation “in consultation with the employer”, which raises the question what should happen if the union delegation and the employer would disagree.



BELGIUM


An employer who would fail to draft the required analytical report, can be imposed a sanction of level 2 in the sense of the Social Criminal Code, i.e. a fine of up to 4.000 €, to be multiplied by the number of workers involved (subject to a cap of 100 workers).

The same sanction can be imposed on a member of the works council or union delegation who illegally discloses the content of the analytical report outside the company. This requires nevertheless that there is sufficient evidence of who precisely leaked the report, which tends in practice to be notoriously difficult to establish for information given to all members of a works council.


Currently unknown.


Are there any other relevant developments/measures in your jurisdiction relating to the gender pay gap that may be worth sharing with clients?

Yes, employers are required to provide equal pay to male and female employees. An employee who files a complaint to the social inspection or a claim before the employment tribunal against the employer based on the aforementioned principle, enjoys a specific protection against dismissal.


CANADA


Pay equality legislation in Canada varies depending on the province in which the business operates and the nature of the business. Some jurisdictions do not have any express pay equity legislation*, some have express legislation which includes assessment and implementation obligations**, and some have legislation which includes assessment, implementation and filing or reporting obligations***. The only jurisdictions with pay equality legislation that applies to the private sector are the federal jurisdiction, Quebec and Ontario.

* Alberta, British Columbia, Newfoundland, Saskatchewan, Northwest Territories, Nunavut and Yukon.

** Manitoba, New Brunswick, Nova Scotia, Ontario, Prince Edward Island, and federally regulated private sector employers and commercial Crown corporations.

*** Manitoba, Nova Scotia, Quebec and the federal public sector.


Manitoba: employers in the broad public sector

New Brunswick: employers in the broad public sector

Nova Scotia: employers in the broad public sector

Ontario: public and private sector employers with 10 or more employees

Prince Edward Island: employers in the broad public sector

Quebec: public and private sector employers with 10 or more employees

Federal jurisdiction: public and private sector employers subject to federal regulation for employment matters, as well as federal contractors (supplies of goods and services to the Federal Government of Canada that are not federally regulated), have 100 or more employees and are bidding on a government contact, supply arrangement or standing offer worth $1 million (CDN) or more.


CANADA


Manitoba:

■ Pay Equity Act came into force in 1985

■ Employers to whom the Act applies were required to implement pay equity through a 3-stage process:

– select a gender-neutral job evaluation system and select male and female job classes to be evaluated

– evaluate the job classes, identify wage inequities and negotiate adjustments with any bargaining unit representing affected employees

– phase in any required wage adjustments over 4 years ■ Employers were required to file pay equity agreements by staggered deadlines, the latest of which was October 30, 1988.

New Brunswick:

■ Pay Equity Act came into force in 2010.

■ Employers to whom the Act applies are required to take such actions as may be necessary to implement pay equity.

■ Employers must ensure that an employee representative is appointed to represent the interests of female-dominated classifications if the employees are not represented by a trade union.

■ Employers were required to report to the Pay Equity Bureau within 25 months of commencement of the Act regarding progress made towards pay equity.

■ Employers must conduct further reviews in accordance with the regulations.

Nova Scotia:


■ The obligations of employers to whom the Act applies were phased in over a period of years depending on the nature of the public sector in which the employer operates.

■ Employers and employee representatives were required to develop an evaluation system within 21 months of the pay equity process applicable to that employer commencing.

■ A pay equity plan agreement made pursuant to the Act must be filed with the Pay Equity Commission.


Ontario:

■ Pay Equity Act came into force 1990.

■ Every employer to whom the Act applies must establish and maintain compensation practices that provide for pay equity.

■ Public sector employers that existed prior to January 1, 1988 and private sector employers who employed 100 or more employees as of January 1, 1988 were required to create pay equity plans.

■ Private sector employers who did not have 100 or more employees as of January 1, 1988 are not required to create pay equity plans, but are required to establish and maintain pay equity.

■ Employers who prepare pay equity plans to which the Act applies must post the plan in the workplace.

■ In March 2018, the Ontario government tabled the Pay Transparency Act, 2018. The anticipated implementation date is January 1, 2019.

■ The Pay Transparency Act, 2018 is intended to promote fairer compensation practices in the private and public sectors. If passed, it would impose further reporting obligations on employers in the province:

– all publically advertised job postings would have include an expected salary rate or range;

– prescribed employers would be required to prepare a “transparency report” containing information relating to the composition of the employer’s workforce and the differences in compensation in the employer’s workforce with respect to gender and other prescribed characteristics; and

– the transparency reports would have to be submitted to the Ministry of Labour and posted online or in a conspicuous location in the workplace.

Prince Edward Island:


■ Employers to whom the Act applies are subject to timelines for the development, negotiation and implementation of pay equity plans.

■ Employers are not required to make annual adjustments under their plans of more than 1% of the previous year’s payroll.

CANADA


Quebec:

■ When an employer reaches 10 employees or more, the employer has 4 years to implement a pay equity exercise. After the exercise is completed, the employer must conduct a pay equity audit every 5 years.

■ Employers must submit a report on pay equity (referred to as DEMES) generally within 6 months after the end of the fiscal year. The DEMES must be filed in French, either online (www.demes.gouv.gc.ca) or by the Annual Updated Declaration that employers are required to submit with the Registrar of Enterprises for Quebec. This report generally contains the type of industry in which the employer is operating, the number of employees working for the employer and if applicable, the date the pay equity exercise results and pay equity audit results were posted in the workplace.


Federal Jurisdiction:

■ Employment Equity Act came into force in 1996. The Act is not limited to gender-based pay equity; its purpose is to redress systemic discrimination in employment against Aboriginal peoples, persons with disabilities and visible minorities as well as women. The Act applies to public and private sector employers subject to federal regulation for employment matters, as well as federal contractors (suppliers of goods and services to the Federal Government of Canada that are not federally regulated), have 100 or more employees and are bidding on a government contact, supply arrangement or standing offer worth $1 million (CDN) or more.

■ A federally-regulated employer subject to the Act must develop a pay equity plan within 18 months of becoming such an employer. The employer must also establish and maintain employment equity records in respect of its workforce, its employment equity plan and the implementation of employment equity. The employer must file an employment equity report with the designated Minister prior to June 1 of each year, consisting of:

– prescribed statistical forms provided by industrial sector, employee status (i.e. permanent full-time, permanent part-time and temporary), occupational group, salary range, hiring, promotion and termination; and

– a narrative of employment equity activities that the employer conducted, including:

– measures taken;

– results achieved following these activities; and

– consultations between the employer and employee representatives.

CANADA


■ In the release of the 2018 Federal Budget on February 27, 2018, the federal government committed to implementing gender-based pay-equity legislation for federally-regulated employees.

■ Although the proposed pay-equity legislation has yet to be tabled, the federal government has reported it will take an “innovative approach” to ensure equal pay for equal work. The legislation would, among other things:

– apply to federal employers with 10 or more employees;

– set out specific timelines for implementation, and compulsory maintenance reviews;

– provide independent oversight; and

– ensure that both wages and other benefits are evaluated in a gender-neutral way.


Manitoba: “Employee” is not defined.

New Brunswick: Employee means “a person who is employed in the Public Service but does not include a chief executive”.

Nova Scotia: “Employee” is defined in the Pay Equity Act as “a permanent employee, whether full-time or part-time, or a term employee employed for a term of more than one year, and includes a regular casual employee”.

Ontario: “Employee” does not include a student employed for his or her vacation period, or a position that provides employment on a casual basis (where work is performed on an irregular and intermittent basis, for less than one-third of the normal work period that applies to similar full-time work).

Prince Edward Island: “Employee” means a person employed by a public sector employer but does not include (i) persons employed to make or conduct a temporary or special inquiry, investigation or examination, on behalf of the Legislative Assembly or the Government, (ii) persons who are patients or inmates in a provincial institution and who help in the work of the institution, (iii) any person paid by fees or hired on a special contractual basis or as an independent contractor, (iv) bona fide students temporarily employed in the period from May to September in any year.

Quebec: “Employee” does not include students working during vacation period, trainees undergoing professional training recognized by law, senior management officers, police officers or fire fighters, and independent operators.

Federal jurisdiction: Employee, for a private sector employer, does not include a person employed on a temporary or casual basis for fewer than 12 weeks in a calendar year. Various, limited exceptions also apply with respect to public sector employers.

CANADA



Manitoba: Pay equity agreements were required to be negotiated with employee representatives or trade union bargaining agents.

New Brunswick: Pay equity agreements were required to be negotiated with employee representatives or trade union bargaining agents. In addition, the employer must ensure that employees affected by the maintenance of pay equity are informed about the maintenance of pay equity from time to time.

Nova Scotia: Pay equity agreements were required to be negotiated with employee representatives or trade union bargaining agents.

Ontario: The employer shall post a copy of each pay equity plan prepared or amended in a prominent place in each workplace to which the document relates and in a manner that can be read by all employees.

Prince Edward Island: The employer must negotiate pay equity agreements with employee bargaining agents and must disclose to employee bargaining agents information relevant to the implementation of pay equity.

Quebec: The results of the pay equity plan will be posted for 60 days in prominent places easily accessible to the employees concerned, together with information concerning the rights exercisable and the time within which they may be exercised. Pay equity audit results (conducted every 5 years) will be posted for 60 days in a similar manner. Employees must be informed of the posting and provided with details such as the posting date, the posting period and how they may access its content.

Federal jurisdiction: Employers are required to provide information to their employees explaining the purpose of employment equity and keep employees informed about the measures which the employer has undertaken or is planning to undertake to implement employment equity. Employers are also required to consult with employee representatives regarding the implementation of employment equity.

CANADA



N/A


Manitoba: Yes. Employers are not required to make annual adjustments under their plans of more than 1% of the previous year’s payroll.

New Brunswick: Yes. Employers are not required to make annual adjustments under their plans of more than 1% of the previous year’s payroll. Employers are to make all required pay adjustments during the 4 consecutive years following the end of the 2011 fiscal year.

Nova Scotia: Yes. Within 24 months of the pay equity process beginning, the parties were required to reach an agreement on the quantum, allocation, and implementation of pay equity adjustments, which were to be completed within a period of four years. All wage adjustments required to achieve pay equity in the Nova Scotia public sector were completed in 1996.

Ontario: Yes. The date by which adjustment in compensation must occur depends on the number of employees working for the employer and whether the employer has posted a notice.

Prince Edward Island: Yes. Employers to whom the Act applies are subject to timelines for the development, negotiation and implementation of pay equity plans, generally within 39 months of the Act being proclaimed in force. Employers are not required to make annual adjustments under their plans of more than 1% of the previous year’s payroll.

Quebec: Yes: adjustments in compensation can be spread over a maximum period of four years. The employer will make the first adjustments on the date by which the pay equity plan must be completed. If the employer fails to do so, unpaid adjustments shall bear interest at the legal rate from the time as of which they were payable.

Federal jurisdiction: Yes. Employers are not required to increase compensation payable annually under the pay equity plan by more than 1% of the employer’s previous year’s payroll.

CANADA



Manitoba: No

New Brunswick: No

Nova Scotia: All wage adjustments required to achieve pay equity in the Nova Scotia public sector were completed in 1996.

Ontario: There are no sanctions specifically related to failing to report or assess. If an employer intimidates an employee in relation to the Act or impedes with a review officer carrying out his or her duties under the Act, the employer is guilty of an offence and on conviction is liable to a fine of not more than CAD50,000.

Prince Edward Island: No

Quebec: If the employer fails to file a report, the employer is liable to a fine of CAD1,000 to CAD45,000.

Federal jurisdiction: If an employer fails to file an employment equity report as required, fails to include required information in the report or knowingly provides false or misleading information in the report, the employer commits a violation and may be assessed a monetary penalty which shall not exceed CAD 10,000 for a single violation and CAD 50,000 for repeated or continued violations.


No information is publicly available about impacts related solely and specifically to pay reporting measures in Canada.

Despite the pay equity legislation which has been variously implemented in a number of jurisdictions in Canada, recent income data provided by Statistics Canada in 2016 indicates that a Canadian woman working full-time makes 73.5 cents for every dollar made by a Canadian man working full time. Even after controlling for gender differences in industry, occupation, education, age, job tenure, province of residence, martial status, and union status, an 8% wage gap persists.

The Federal Government’s 2015 Annual Report on the Employment Equity Act indicates that since 1987, the representation of women in the federally-regulated private sector has increased from 40.9% to 41.4%.

CANADA



Some jurisdictions with no pay equity legislation have developed policy frameworks for negotiating pay equity, but typically just with public sector employees and/or unions.


Equal pay for equal work provisions can also be found in human rights and employment standards legislation in some jurisdictions.

CANADA



No


No


No. The gender pay gap is not a well-developed concept in China and no direct rules/measures have been introduced to date. In China, the laws and regulations set out general principles around eliminating any pay gaps, but these do not specifically focus on pay gaps caused by gender.

CHINA


DENMARK


Yes. Employers are required to send in information regarding pay to Statistics Denmark, who will provide the employers with gender segregated pay statistics.


Private and public employers with 35 or more employees and at least 10 employees of each gender with the same work function. The employees are categorised in regards to work function with a 6-digit “DISCO”-code. Employers are required to send in information on pay for all employees who are paid according to the amount of time they have worked. Employees who are paid according to performance are not covered by these rules.


Employers are required to send in information regarding pay to Statistics Denmark, who will provide the employers with gender segregated pay statistics once every year. The statistics show the difference as a percentage difference between the salary of men and women in each employment category with at least 10 women and 10 men.

By agreement with employees/employee representatives, employers can choose to make a statement on equal pay instead of the equal pay statistics. The statement must contain:

■ a description of factors that have an influence on the remuneration of men and women at the company,

■ a plan for how the company intends to prevent or reduce the pay gap between men and women and

■ a follow-up procedure.


Employees only.


Employees are entitled to receive information regarding the pay statistics and/or statement under the general rules on employee information and consultation.


DENMARK


No


The employer is not directly obligated to close the gap, however the statistics may give an indication that there are grounds for legal proceedings against the employer for violation of the Equal Pay Act.


If employers fail to report to Statistics Denmark, the employers are then obligated to produce their own statistic on equal pay. An employer may also be subject to a fine, if the employer fails to comply with these rules.


There is still a pay gap between men and women corresponding to approximately 13-17%. In 2015, the scope of the rules on equal pay statistics were changed to cover even more employers due to the fact that the rules did not have the desired impact. Only one third of the employers covered by the rules complied with them. The rules were changed back to the original form at the beginning of 2016.


N/A


The Danish Institute for Human Rights is especially appointed in connection with further equal treatment of all people regardless of gender, race or ethnic origin. In 2014, the institute published a report on the issues of equal pay and provided recommendations on how to solve the problems. The institute has a mandate to bring cases before the Danish Board of Equal Treatment on its own initiative.


FINLAND


Yes. According to the Finnish Equality Act, employers are required to produce an equality plan every second year particularly with relation to pay and other terms of employment.


Private and public employers with 30 or more employees on a regular basis.


The equality plan shall include a pay survey ensuring that there are no unjustified pay differences between women and men who are working for the same employer and engaged in either the same work or work of equal value. The pay survey must include:

■ details of the employment of women and men in different jobs;

■ a survey of the grade of jobs performed by women and men; and

■ the pay for those jobs (including bonus etc.) and the differences in pay.

The disclosed data cannot be linked with any individual employee.

The equality plan must include:

■ analysis of the state of equality at the workplace and in different areas of employment;

■ necessary measures planned for introduction or implementation with the purpose of, inter alia, achieving equality in pay; and

■ a review of the extent to which measures previously included in the gender equality plan have been implemented and of the results achieved.


The duty applies to all employees in each personnel group.


FINLAND


Yes, the employer has a statutory obligation to inform the employees about the equality plan (including the pay survey), its content and any amendments to it. Further, all employee representatives taking part in the pay survey must have access to the information for carrying out the survey (including the information in line with the classification system used on the average salaries of women and men as well as more detailed information on salaries according to salary component if required).


The equality plan must be available to the employees.


At first, the employer must account for reasons behind any pay gap. If no acceptable reason is found for the pay gap, the employer shall take appropriate corrective action.


If an employer neglects to produce the equality plan several times, the National Non-Discrimination and Equality Tribunal may impose an obligation on the employer to prepare an equality plan within a defined period, under threat of a fine if necessary.


The equality plans and the pay surveys included thereto are deemed useful in furthering gender and pay equality. Many employee representatives have started drafting a missing equality plan or updating an existing equality plan together with their employer. (In 2010, 62 % of workplaces reported a valid equality plan, 14 % reported of an equality plan in the making). However, according to some employees, the handling of and discussions on equality plans have been inadequate or even non-existing in the workplace.


N/A


FINLAND


No such measures or developments have been initiated.


FRANCE


Yes. All companies must ensure gender equality for their employees as a general rule. In addition, in companies with at least 50 employees, a written comparative, male-female status report must be drawn up every year, on the basis of which the works council is consulted every year.

The employer is bound by a legal obligation to inform and consult the works council annually on gender equality. The employer must also negotiate a collective agreement annually with the union representatives on gender equality aimed at closing any gender pay/career gap and following up on measures taken to closing any gaps identified.

In the absence of collective agreement, companies must implement a unilateral gender equality action plan in order to defined progress targets (in companies with at least 50 employees).


Private employers with at least 50 employees.


For employers with at least 50 and less than 300 employees: The report must analyse the situation of men and woman for each professional category regarding remuneration and career evolution.

For employers with 300 employees or more: The report must address additional matters prescribed by the Labor Code. It is possible for the company to add other indicators regarding its particular situation. The indicators are the following:

■ The Company’s pay range,

■ Average or median monthly pay,

■ Number of women in the top 10 pay.

These indicators provide both figures and explanatory data. Figures shall be given by gender, by seniority and by age.

The Company’s database (on which the report and the collective agreement/unilateral plan are available) must also provide a diagnosis and an analysis of the situation of men and woman for each professional category regarding remuneration, and an analysis of pay/career disparities according to age, job, and seniority.


The duty applies to all salaried employees.


FRANCE


Yes: Employee representatives are consulted every year on gender equality; union representatives negotiate on it every year. In addition all employee representatives have access to the information made available on the Company’s database.

The collective agreement on gender equality, or the action plan are posted on the company’s relevant notice boards, intranet and kept available for any person requesting it.


An overview of this action plan must be published on the company’s website (if one exists), and communicated to the Labour Inspector.


Any provision according to which employees are paid less than employees of the other gender for a same work or for work of equal value is null and void. Therefore, these employees can benefit from the highest remuneration paid to the other gender employees.

Taking measures is mandatory and followed up every year through a negotiation and works council consultation regarding objectives of gender equality and pay equality.


Financial penalty: Companies with at least 50 employees can be fined if they have no applicable collective agreement on gender equality (including measures on pay equality), or a unilateral gender equality action plan. The amount of the fine is set by the labor administration, depending on the efforts made by the company to comply with its obligations, but can be up to 1% of payroll. Employers may ask for an administrative opinion (“rescrit”) on their practices to make sure they are compliant and avoid payment of the 1% penalty.

Exclusion from the public procurement procedure: Companies with no applicable collective agreement on gender and pay equality can be excluded from the public procurement procedure for up to 3 years.

Remuneration: Any provision according to which employees are paid less than employees of the other gender for a same work or for work of equal value is null and void. Therefore, these employees can benefit from the highest remuneration paid to the other gender employees.

Penalty in case of non-compliance with provisions regarding pay equality: The employer can be fined to EUR 1,500. For corporate entities, the fine may be up to EUR 7,500. The sanction is doubled in the event of a repeated offence. The fine is payable as many times as there are non-compliant paid workers.


FRANCEWhat has the impact been of any pay reporting measures introduced in your jurisdiction?

Pay equality is clearly a highly topical issue of major importance for successive governments. It is noted that national legislation on this matter is continuously strengthened.

Following the Labor Ministry’s May 2018 announcement of an action plan to tackle equal pay, the Law for Freedom to Choose a Professional Future was approved on 4 September and published in the Journel Officiel on 6 September 2018. Under the action plan and legislation:

■ Companies with 50 or more employees will be required to publish information annually on the size of the pay gap between male and female employees by 1 January 2019 (businesses with more than 250 employees) or 1 January 2020 (businesses with 50 to 250 employees).

■ The methodology for calculating the pay gap is currently being considered. Where a wage gap persists, the company will have to set aside a “wage catch-up budget” for women. This budget will be agreed as part of the existing negotiations or professional equality or, in the absence of agreement, will be set by the employer after calculation with the Social and Economic Committee.

■ If after 3 years a wage gap persists which is above a minimum rate set by Ministerial Order the employer may be subject to a financial penalty.

■ Businesses will be obliged to publish gender pay gap information on their website and to give elected worker representatives access to more detailed data. They will be also required to publish information on how the company intends to implement equal representation of women and men in executive roles and in the top 10% of senior roles within the organisation.

According to the labor administration, it appears that larger firms are the more compliant. 79% of companies with at least 1000 employees are covered by a collective agreement or an action plan regarding gender equality (including pay equality) vs. 32% of companies with between 50 and 300 employees.


When the law comes into effect.

Are there any other relevant developments/measures in your jurisdiction relating to the gender pay gap that it may be worth sharing with clients?

No


GERMANYAre employers under a legal duty to assess and/or report on gender pay differences?

Yes – The Remuneration Transparency Act came into force on 1 July 2017, which imposes an express legal duty for employers to assess and/or report on gender pay differences.


In operations with more than 200 employees in one operation:

■ Individual employees will have a right to request information about the average pay of comparable employees of the opposite gender but only where there are at least 6 employees of the opposite gender in comparable positions (for data privacy purposes, so that no individual salary data is disclosed). This right can only be exercised after 6 months after the law came into force.

■ The request can cover information about the comparable employee’s base salary plus two additional pay components, e.g. bonus, car allowance, etc.

■ We expect a definition of comparable work to be introduced for this purpose.

Also, employers with more than 500 employees across the whole business are:

■ “Encouraged” to implement a regular audit to determine any pay gap and if necessary develop countermeasures but there is no legal obligation to do this.

Also employers with more than 500 employees and who are under an obligation to publish management reports are:

■ Required to publish management reports about their measures to ensure equality and equal pay and their effects every 3 years (6 years if collective bargaining agreements are in place).


Please refer to our answer regarding the previous question.


The duty does apply to employee pay and trainee pay.

However, temporary workers are generally covered by an equal pay principle. The Germany Temporary Workers Act gives the temporary workers the right to request information regarding the pay of a comparable employee at the company which is leasing the temporary workers.


GERMANY


The management report about measures to ensure equality and equal pay and their effects has to be made publicly available.


The management report has to be published in the Federal Gazette (Bundesanzeiger).


The employer shall take appropriate steps to close the gap. In addition, employees have a right to equal pay. If their pay is lower than the remuneration of comparable employees, they can raise a claim for equal payment.


Please refer to our previous answer. There are no further sanctions.


The remuneration Transparency Act came into force on 1 July 2017 and the right to request information came into effect 6 months later. It is therefore still too early to tell whether the reporting measures will have any impact in Germany.


Employees are encouraged to implement a regular audit to determine any pay gap and if necessary develop countermeasures but there is no legal obligation to do this.


No


HONG KONG


No


The Hong Kong Equals Opportunities Commission encourages employers to perform a self-audit as a proactive approach to achieve equal pay in the workplace.

The self-audit should:

■ examine the actual pay practice within the company

■ identify equal work and work of equal value

■ conduct pay analyses and

■ formulate a pay equity plan


No


INDIA


Yes. Whilst there is currently no law in India dealing directly with the gender pay gap, the Equal Remuneration Act, 1976 (ER Act) has been enacted in India to secure equal pay for equal work for both men and women. Under the provisions of the ER Act and the Equal Remuneration Rules, 1976 (ER Rules), an employer is required to maintain a register in the prescribed form (Form D) with respect to all the workers employed. The form contains details relating to the description of work, the number of men and women employed, the rate of remuneration paid and the breakdown of the components of the remuneration.

Hence, while there is no direct obligation to report/submit the data under the ER Act, the employers are under an obligation to maintain the data in Form D for assessment by the labour inspectors.


The ER Act came into force for different categories of employers over a period of time through various notifications by the central government. Through the years most categories of employers such as the employers in manufacturing, information technology, financial services etc., have been notified under the ER Act.


As we have mentioned in our response to question 1 above, an employer is required to maintain a register in Form B, which has information relating to the description of work, the number of men and women employed, the rate of remuneration paid and the breakdown of the components of the remuneration.


While the obligations under the ER Act are only applicable for employees, there is a separate legislation – Contract Labour (Regulation and Abolition) Act, 1970, which deals with third party contract workers. Under this legislation, one of the conditions for granting a license to the contractor is an undertaking from the contractor to provide equal pay for equal work. There are also obligations to maintain registers with wage details. There is however no reporting obligation.


The obligation under the ER Act is to only make the register available to the authorities appointed under the ER Act.


There is no obligation on the employer to publish the registers maintained under the ER Act. The only obligation is to maintain the registers for assessment by the labour inspectors.



The obligation under the ER Act is only to provide equal pay for equal work on an individual basis.

What is/are the sanction/s for non compliance (if any)

Under the ER Act, if an employer fails to comply with the provisions relating to the maintenance of the information, then the employer could be punished with an imprisonment for 1 month or a fine of INR 10,000 or both. If the employer fails to comply with the provisions relating to the recruitment or payment of remuneration, they shall be punished with a fine not less than INR 10,000 (which extend upto INR 20,000) or with imprisonment for a term of 3 months (which may extent to 1 year) or both.


As we have mentioned, there are currently no pay reporting measures in India.


There are currently no initiatives in India by which employers are encouraged to assess or report on the gender pay differences.


The ER Act also places an obligation on the employers to not discriminate on the basis of sex in the matters relating to recruitment, promotions, training or transfer.


IRELAND


Not at present. Note, however, that the Government has pledged to introduce measures to reduce the gender pay gap and a draft bill, introduced in 2017, proposed that all organisations with 50 employees or more would be required to publish gender pay gap information. A new bill – the Gender Pay Gap (Wage Transparency) Bill 2018 now proposes that the requirement will apply initially to businesses with 250 or more employees, reducing to 150 and subsequently 50.


N/A


N/A


N/A


N/A


N/A


N/A


N/A



N/A


N/A


A private members bill, the Irish Human Rights and Equality Commission (Gender Pay Gap Information) Bill 2017 (“the Draft Bill”) was initiated by the Labour party back in May 2017. It provides that an organisation with more than 50 employees may be obliged to publish certain information on the gender pay gap.

Subsequently the Government indicated its intention to give drafting status to a new Bill – the Gender Pay Gap (Wage Transparency) Bill 2018. The draft Bill requires employers to publish data setting out the difference in average hourly and bonus pay for men and women, and the number of men and women across a few different pay categories. It is anticipated that Irish employers that fail to comply with the reporting requirements will, amongst other enforcement mechanisms, face significant fines.


ITALY


Yes


Private and public employers with more than 100 employees.


The employer must draft a report on the situation of male and female personnel in the following areas:

■ Hiring

■ Training

■ Professional promotion

■ Enrolment level

■ Changes of category or qualification

■ Redundancy events

■ Intervention of wage integration fund

■ Dismissals

■ Early retirements and retirements

■ Remuneration actually paid


Employees only.


ITALY


Yes, the report has to be provided, at least once every two years, by 30 April, to the work councils and to the “Regional Counselors for Equal Treatment”. The report is then reviewed by the Counselors and sent to the “National Counselors for Equal Treatment”, to the Labour Ministry and the Equal Treatment Department of the Government.


No


In order to close the gap the employer may adopt appropriate measures (take positive action) with the aim of removing any obstacles to equality between men and women. Employees who believe they have been discriminated against may also start individual or collective legal action themselves or through the “Counselor for Equal Treatment”.


Italian law provides the following sanctions for non-compliance:

■ If the employer, at least every 2 years, does not send the report to the persons indicated by the law, the Regional Labour Office may ask the companies to provide the report within 60 days;

■ If the employer does not fulfil this obligation it must pay an administrative sanction from EUR 103.00 up to EUR 516.00;

■ In case of proven discrimination regarding hiring, professional training, equality treatment for pay, duties and career and retirement age, the employer must pay an administrative sanction from EUR 5,000.00 up to EUR 10,000.00;

■ If the employer does not comply with the Court order subsequent to the individual or collective action the sanction is the imprisonment up to 6 months or a fine up to EUR 50,000.00.


This is not a matter of public record.


ITALY


N/A


No


JAPAN


The Labor Standard Act of Japan prohibits discrimination in salary based on the fact that the employee is female (Article 4). The Act on the Promotion of women’s Participation and Advancement in the Workplace requires companies which have more than 300 employees to research and understand, as a minimum, the company’s (i) rates of newly hired female employees; (ii) the gender gap for years of continuous employment; (iii) working hours; and (iv) rates of female managers.

In addition, such companies have to prepare and submit an action plan based on the foregoing research to the Minister of Health, Labour & Welfare. The plan should include (i) terms of the plan; (ii) targets; (iii) content; (iv) timing.


The Ministry of Health Labor & Welfare carry out statistical research every year on employee salaries in Japan. In such research, the Ministry ask employers who are randomly selected to answer questionnaires regarding salary (i.e. type of business, type of employment, gender, full-time/part-time, school history, age, length of service, title salary/bonus/overtime amount etc.). However, there are no penalties for employers even if the employers do not respond. According to the Ministry’s web page, in 2016, out of 65,811 companies with 10 or more employees, 49,783 answered the survey.


See above.


MEXICO


No. Although the Mexican labor law establishes an equal pay obligation, there is no obligation to report.


No


No


NETHERLANDS


No


Currently, Dutch law provides no special legislation that obliges employers to assess and/or report on gender pay differences. There is legislation that imposes general restrictions relating to discrimination. Based on this legislation, employers are prohibited to make a distinction between men and women. This includes terms of employment, so equal pay is covered by this as well. In case an employee is of the view that a distinction is made (wrongfully), he/she can to go to court.


A legislative proposal on transparency regarding equal remuneration is currently progressing through the Dutch parliamentary system. The proposal would impose a legal duty on employers to report on equal pay in the annual report. In addition, the works council would need to authorise policies on equal treatment of men and women with respect to (all aspects of) remuneration. Also, the works council will be allowed to conduct an inquiry to the equality of payment within the company. The debate on the legislative proposal in parliament is currently on hold and it is unclear if/when the proposal will be debated in parliament again.


1 Jf. likestillingsloven § 24

NORWAY


Employers who are subject to certain accounting obligations and public employers have a legal duty to report on gender pay differences.


Employers who are subject to certain accounting obligations and all public authorities and companies who are not required to prepare annual reports.


The employers that are covered by the legal duty to report on gender equality shall every year create a report on the actual state when it comes to gender equality in their operation.1 The report shall also include a description of equality measures that have been implemented and equality measures planned for implementation.

The employer shall include information that is designed to reveal unintended and undesirable differences between men and women in the corporation. The information should describe the gender ratio, preferably by percentage, in the following areas: wages and employment levels.


The duty is likely to include both employee pay and the pay of other workers.


No, there are no obligations to give the report to employees or their representatives. However, depending on the company’s structure, the Board may be obligated to present the report to the General Assembly and the Corporate Assembly.


No, the report does not have be published. The report shall, however, be “public”. Everyone has the right to see the report upon request. Additionally, the report shall be filed together with the annual financial statement to the Accounting Registry, where everyone can access it upon request.


NORWAY


Employers who are obligated to report on gender equality are also under a duty to actively work to achieve gender equality, hereunder gender pay equality.


No direct legal sanctions. However, deficient reporting on gender pay equality can, at worst, result in the annual report being considered not filed as required, which in turn can result in fines. However, this is not likely to happen.

Non-compliance can also result in reputational risk.


No available information.


N/A


No


PHILIPPINES


No, there is as yet no legal duty to assess and/or report on gender pay differences.


N/A


N/A


N/A


N/A


N/A


N/A



N/A


N/A


N/A


N/A


POLAND


No


No. Nevertheless, employers are obliged to observe a general statutory rule of equal treatment, obliging them to grant equal pay to employees performing the same work or work of equal value. However there are no specific tools allowing the Polish authorities to monitor gender pay differences.


No specific measures relating to gender pay reporting. In general, employees whose terms of remuneration have been established to be in breach of the equal treatment rule are entitled to demand compensation from their employer. The compensation cannot be lower than the statutory Polish minimum wage (in 2017 PLN 2000) but the law does not specify the maximum amount of compensation. The Supreme Court has confirmed that the compensation should be proportionate to the employer’s breach as well as acting as a deterrent. In practice, the affected employee may demand the difference between his/her current remuneration and the remuneration received by employees in comparable positions. In addition, a labour court can decide on the level of remuneration applicable to the employee in the future.


ROMANIA


No – there is no express legal duty for employers to assess and/or report on gender pay differences.


There are no specific provisions/measures aiming at encouraging employers to assess and/or report on gender pay differences.


■ General non-discrimination law: expressly refers to non-discriminatory access between men and women to equal pay for equal work, failure triggers fines up to approx. EUR 22,250.

■ National Strategy for equality between women and men for 2014-2017: provides for actions of state bodies and NGOs to organise meetings to raise awareness of private sector employers about the importance of reducing the pay gap between women and men.

■ The Romanian National Institute for Statistics, which has access to a wide range of information, is required to develop gender-based statistics and to assist in the implementation in Romania of the gender equality indicators promoted by the European Commission.


RUSSIA


No


No


No


SPAIN


There is no specific legal obligation to assess/report on gender pay differences. Those differences would be contrary to the Fundamental Right to Equal Treatment set out in the Spanish Constitution. Workers’ Statute states that employers shall pay an equal salary for the rendering of equal services without differences based on gender (or any other discriminatory grounds). Any discrimination in employment conditions (including pay) may be sanctioned with an administrative fine up to EUR 187,515.


Employers have a legal obligation to avoid any pay differences based on any discriminatory ground.


■ Companies (1) with more than 250 employees or (2) companies which have collective bargaining agreements/internal company agreements which set out an obligation to have a gender equality plan, must have a gender equality plan, which covers, amongst other things, matters related to wages;

■ Employees’ reps are entitled to receive information related to the application of the right to equal treatment in the company; and

■ Companies may apply for an equality award provided certain legal requirements are met (the relevant authorities assess, amongst other things, equal salary treatment for men and women and once the award is granted, the company should prepare an annual report on gender pay amongst other things).

In addition, Public Authorities provide tools to assess the gender pay gap that companies may use voluntarily.

In August 2018, the Spanish Government published a draft, ‘Master plan against labor exploitation 2018-2019-2020’. This plan contains a number of operational measures which are to be implemented by the Labor Inspectorate, including a measure to reduce the gender pay gap. The Socialist Parliamentary Group is also focusing on new laws to ensure equal treatment for men and women in terms of pay.


SWEDEN


Yes

In Sweden a mandatory gender pay reporting regime was first introduced in 1994. Since then the rules has been subjected to a few changes and the present wording that is found in the Swedish Discrimination Act (Sw. Diskrimineringslag (2008:567)) has been in force since 2009.

Under these rules employers with at least 10 employees are obliged to conduct an annual review of its applied practice in regard of salary and other employment conditions. The result of such review shall be presented in writing and analyzed in regard of e.g. existing salary differences between men and women that are performing the same or equivalent work or in regard of professions that are typically dominated by women. By this the employer shall assess whether existing salary differences has a direct or indirect connection to gender.

Examples of practical issues that follows from this kind of regulation could be difficulties in identifying types of work that are comparable and assessing whether a certain profession is to be qualified as dominated by women.

However, to our knowledge the main practical issue in Sweden in regard of these rules is that there is a wide-spread lack of awareness of amongst employers in general about their obligations in this regard.


Employers with at least 10 employees.


Employers are obliged to conduct an annual review of its applied practice in regard of salary and other employment conditions. The result of such review shall be presented in writing and analyzed in regard of e.g. existing salary differences between men and women.


In Sweden there are no differences between an employee and worker. The rule applies for all employed persons.


The local union representatives will have access to the report.


SWEDEN


No


Yes, if the pay gap cannot be reasonably explained by other reasons, such as education and skills for instance. The employer is under an obligation to close any unexplained gap.


The relevant authorities – The Equal Opportunities Ombudsman – (Sw; Diskrimineringsombudsmannen) may conduct inspections and decide on liquidated damages and fines.


There is still a pay gap between men and women that cannot be explained by other reasons than sex. The overall impact is that employers are forced to conduct the survey.


Please see above.


No


UAE


No, employers are not required to report on gender pay differences.

The Federal UAE Labour Law of 1980 states that where a woman is performing the same work as a male counterpart she should receive the same remuneration, however employers’ compliance with this provision is not monitored.

With regard to the Dubai International Financial Centre there are no specific provisions in the legislation which address equal pay directly, however the discrimination provisions are likely to be relied upon if there is a pay differential where a man and a woman perform the same work.


No


No


UK


Yes – for pay data as at April 2017 onwards.


Private and public employers with 250 or more employees on the “snapshot date” (which is 5 April in the relevant year).


Annual pay gap report to be produced, signed by a director (or equivalent) of the relevant entity and published on the UK website. Report to show:

■ Overall mean gender pay gap for full-pay employees

■ Overall median gender pay gap for full-pay employees

■ Mean bonus pay gender gap over past 12 months

■ Median bonus gender gap over past 12 months

■ Proportion of male and female employees who receive bonus

■ Pay quartiles gender split for full-pay employees

No data on actual individual pay rates is required to be disclosed – just the percent differences/ratios.


“Employee” is not defined. However, further guidance explains that the wider definition of employment under section 83 of the Equality Act 2010 applies. “Employee”, therefore, is anyone employed under a contract of service, a contract of apprenticeship or a contract personally to do work. This will include employees, casual workers and some contractors.


UK


No, there is no obligation to give the report to employees or their representatives unless there is a separate duty to do this under a collective agreement, but obviously, once it is published on the employer’s and Government’s website, it is publicly accessible regardless.


It must be published on the company’s UK website and the employer must retain the information online for three years. It must also be published on the Government website, with the name of the director.


No


There are no provisions for legal sanctions/fines in the legislation itself, but the Equality and Human Rights Commission (EHRC) consider it has the power to take enforcement action on the basis that a failure to comply would be an ‘unlawful act’ under the Equality Act 2010. The EHRC has published its enforcement strategy which comprises writing to the employer in the first instance followed by an investigation and ultimately the issuing of an unlawful act notice and the application for a court order in the event of continuous non-compliance.


Employers were required to publish their first reports by 4 April 2018. Over 10,000 did so with many setting out their action plans for reducing any gender pay gaps identified. Over 1000 employers did not report on time, but the EHRC wrote to those employers requiring them to comply within 28 days and the majority either reported or confirmed that they were not subject to the reporting requirement. A report by the BEIS Select Committee published on 23 July 2018 has made a number of suggestions for amendment to the gender pay gap reporting requirements, including more stringent and simplified enforcement.


UK


N/A


No


USAre employers under a legal duty to assess and/or report on gender pay differences?

Not at present. The EEOC proposed new regulation which would have applied from March 2018 (retroactively for 2017) but the requirements were halted before they took effect.


Currently none. The EEOC proposals applied to employers with over 100 employees.


If the EEOC proposals are ever brought into force EEO-1 reporting requirements would be expanded to include pay data. There are 12 salary bands on which the EEOC wants data; it demands that data separately for each of the 9 EEO-1 job categories (professionals, technicians, craft workers, etc.) and for each of the 14 traditional race/sex categories. So, 12 x 9 x 14=1,512 for the number of employees and the same for the aggregate hours.


The EEOC proposals only apply to employee pay because this is based solely on collecting W-2 tax reports (independent contractors and other workers do not receive a W-2).


No. Under the EEOC proposals this would only go to the Equal Employment Opportunity Commission.


No publishing.


USIf a pay gap is identified is there any duty to take steps to close the gap?

No. Even if the EEOC proposals became law, assessment of data will not be required by employers, but EEOC will analyze and identify “statistics of interest” by comparing company information with the industry or metropolitan-area.


If the EEOC proposals became law, the EEOC will be able to have a federal court compel the publication of the report.


Not in force.


There has been a recent movement by private shareholders to force publically traded companies to report pay gap information to shareholders and to rectify any gap found.


Several states are eliminating statutory defenses to pay gaps. The federal law compares the same jobs, whereas some states have moved to similar or comparable jobs. Similarly states are eliminating affirmative defense of reliance on a “differential based on any factor other than sex,” and requiring employers to only base pay gaps on a bona fide factor other than sex or to eliminate pre-employment inquiries on salary history.


ABOUT THE EMPLOYMENT GROUP

DLA Piper’s Employment group is a market-leading global practice with a strong reputation for delivering solutions-based advice and supporting clients in the day-to-day management of their people legal issues and risk. It includes over 300 specialist lawyers globally, on a strategic and operational level, on both contentious and non-contentious matters across the public and private sectors. The group advises on all areas of employment, including trade union and employee relations, discrimination and diversity management, global mobility and data privacy. We also advise on the legal, tax and regulatory aspects of remuneration, employee share incentives and other benefits, and we assist clients generally in designing and delivering their reward strategies.

This survey provides a headline review of gender pay reporting obligations in the countries identified as of September 2018. Obviously, this is by way of guidance only and is not a substitute for full legal advice.

FOR FURTHER DETAILS ABOUT THIS SURVEY PLEASE CONTACT

Clare Gregory Partner Sheffield T +44 333 207 7740 [email protected]

Kate Hodgkiss Partner Edinburgh T +44 333 207 7827 [email protected]

For details of all our services or to obtain a copy of our training directory, visit www.dlapiper.com/globalemployment.

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