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Cracking the code on pay transparency

Questions from the webinar

As we ran out of time and didn’t make it through all your questions, we’ve gathered the answers from Pihr here:

Q and A

What is the proper meaning of reporting different pay gaps? Median, average?

The directive requires the employer to publish aggregated pay gaps for both the mean and median, however, for position pay gaps it refers to only publishing and explaining pay gaps based on the Mean salaries.

Are companies obligated to share what each individual earns regardless of position/team/group?

The right-to-information part of the directive means that any employee will be allowed to

ask about their individual pay compared with their peers in equal and equivalent

positions. This basically means that an employer needs to share the employee’s salary in comparison with the average salaries of workers considered doing work of equal and/or equivalent value.

As a rewards leader, in the past, I have implemented salary ranges and hiring ranges, the difference being that the hiring range is within the salary range, the salary range being broader to consider internal talent and development. Do you think putting the hiring range on the job ad, with the transparency of the salary range being broader for internal talent with proven performance and career development, will be ok?

Yes, under the EU Pay Transparency Directive, including a hiring range within a broader

salary range in job advertisements is acceptable. The directive requires employers to

provide job applicants with information about the starting salary or pay range for

advertised positions, either in the job vacancy notice or prior to the interview process. This information must be based on objective, gender-neutral criteria attributable to the relevant position.

If an employee asks how their salary compares to others with the same or equivalent work – what are we as employers obliged to answer? Should we state whether the salary is below, in the middle or above the average – or do we have to state the exact level/how many are included/roles

The directive grants employees the right to request information on their pay level and the

average pay levels, broken down by sex, for categories of employees doing the same

work or work of equal value. Employers are obliged to provide this information upon

request. While the directive does not mandate disclosing exact salaries of other

employees, employers should provide sufficient information to allow employees to

assess whether they are being paid fairly compared to their peers. This could involve

stating whether an employee’s salary is below, at, or above the average for their role. Employers should also ensure that the information provided respects data protection and privacy regulations.

Is the pay transparency limited only gender pay differences or do we need to also justify pay differences for males working in the same role?

The directive focuses on the underpaid gender in each position. So if the males are earning more than females in a position, no explanations around differences between the males are needed. Please note! That each country might have other pay equity legislation that addresses the issue.

Should Management Team salaries be included to salary statistics or can they be excluded?

All employees (including management positions) should be included in the calculation of the gender pay gap of the organization.

I would presume salary criteria and Performance mgmt also has to be VERY much transparent? SO employees could earn more money in their position.

Yes, Performance evaluation processes must be transparent and understandable. Employees should be clearly informed about how performance impacts their compensation and career development opportunities. Employers should clearly define and communicate the metrics and processes used for assessing performance to ensure

fairness and objectivity