On Tuesday, 10th May 2022, the Irish government released a guidance note to employers on how to conduct their Irish gender pay gap mandatory reporting calculations. Details were given on the steps companies with 250 or more employees need to take in order to calculate their gender pay gap statistics for their chosen snapshot date in June 2022. Publication of the calculations will be required on the company’s website on the mirror date in December 2022.
Subsequently, the Irish government published the Gender Pay Gap Reporting Regulations in full on the 3rd of June, 2022. The Regulations are available here. The Regulations form the legal basis for the method to conduct an employer’s gender pay gap calculations under the Gender Pay Gap Information Act 2021.
The Regulations clarify a number of key areas including:
Gender pay gap reporting along with the Central Bank of Ireland’s (CBI) focus on diversity and inclusion as part of the Individual Accountability Framework (IAF) in regulated firms will continue to put a spotlight on Irish insurance companies. The CBI has noted previously that it “considers a lack of diversity and inclusion at senior management and board level in organisations to be a leading indicator of elevated behaviour and culture risks” with a gender pay gap within an organisation typically being an indicator of a lack of gender diversity at senior levels.
In October 2021, the Financial Times identified the insurance industry and wider financial services sector as having one of the most pronounced pay gaps of any sectors, with the lack of women in senior roles identified as the main driver of this. To address, insurance companies in the UK are promoting a wide range of initiatives such as flexible working, creating an inclusive work environment, examining recruitment methods, and their promotion process.
Objective
Gender pay gap reporting is part of a wider government strategy to address gender participation rates and parity in the Irish workforce. The objective of gender pay gap reporting is to:
The Calculations
The calculations require companies to calculate the following:
The calculations require employers to calculate the total ordinary pay, total bonus, and total benefits in kind for each employee on the snapshot date, along with the hours they worked during the reporting period (snapshot date to the day after the snapshot date in 2021 i.e. if snapshot date is June 24 2022, the reporting period will be 25 June 2021 to 24 June 2022).
Employers should also note which employees are full-time employees, part-time employees, or on temporary contracts over the reporting period.
What Immediate Steps Should Companies be Taking?
For more information or assistance on how your organisation should approach their gender pay gap calculations, the review of calculations already completed, and the formulation of a gender pay gap strategy, please contact our team of experts below.
This article originally appeared in the Insurance Ireland Diversity & Inclusion Update, June 2022.