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1. Background

The Gender Pay Gap Information Regulations require all employers with 250 or more employees to report their Gender Pay Gap annually, publishing on a national Government website as well as the organisations website. The Gender Pay Gap Information Regulations apply to employers in the Public and Private sector.

In addition to these new regulations, employers in the public sector are subject to a specific public sector equality duty in respect of their functions – The Equality Act 2010 (Specific Duties and Public Authorities) Regulations 2017.

The regulations apply to all employers with 250 or more employees on the “snapshot” date. The “snapshot” date for the public sector is 31st March each year. Therefore, the authority is required to publish its gender pay gap for each year on the Portsmouth City Council (PCC) website and on a Government website, no later than 30th March of the following year. So for the snapshot date of March 2020, the findings must be published no later than 30th March 2021.

The purpose of Gender Pay Gap reporting is to achieve greater gender equality across the UK and increase pay transparency. It has been estimated that the under-utilisation of women’s skills costs the UK economy 1.3 – 2% of GDP annually, and that eradicating the full-time gender pay gap would contribute additional spending into the economy of £41b each year.

In 2020 the national gender pay gap for full-time employees was 7.4%, meaning that average pay for full-time female employees was 7.4% lower than for full-time male employees. This is a slight decrease since 2019, where the gap was 9%. The national gender pay gap for all employees, full and part-time is 15.5% which is a slight decrease from 2019 when it was 17.4%. It is important to note that the Coronavirus pandemic and the furlough scheme may have an artificial impact on the national gender pay gap figures for 2020/21.

The Government considers that this rate of progress is too slow, and has committed to closing the gender pay gap within a generation.

PCC is committed to the principle of equal pay for all employees by ensuring that it meets the requirements of the Equality Act. To achieve this PCC uses a job evaluation system scheme (JESS) to assess the value of all jobs across the organisation, which provides evidence in support of the banding of each job within our grading structure. Salaries are paid according to band and incremental annual progression within the band occurs irrespective of employee’s gender.

Whilst the data on the age breakdown is not a statutory requirement under the legislation, this data has been included at the request of our Members. The ONS has published some national data on the age breakdown and the same categorisation and calculations used by the ONS have been replicated for the breakdown of the data for Portsmouth City Council.

Sources:

ONS Gender Pay Gap in the UK: 2020

ONS Employee Earnings in the UK: 2020

2. Methodology

The Regulations clearly define the methodology for the Gender Pay Gap calculations and reporting guidelines.

The regulations require employers to publish the following information:

  • The mean gender pay gap;
  • The median gender pay gap;
  • The mean bonus pay gap;
  • The median bonus pay gap;
  • And the relative proportions of male and female employees in each quartile pay band.

The Regulations detail how to carry out the calculations and these are based on how the ONS undertakes their calculations to allow for comparisons to be made nationally against the data.

All public sector organisations are required to publish their reports by no later than 30th March of the following year.

The report will be based on hourly pay rates as at 31 March 2020 and on bonuses paid between 1 April 2019 and 31 March 2020.

3. Scope

The regulations create two categories of people who have to be taken into account in the gender pay gap reporting: relevant employees and relevant full-pay employees.

For the purposes of gender pay gap reporting, the definition of an employee is that which is given in the Equality Act 2010. This is an extended definition which includes:

  • Employees (those with a contract of employment)
  • Workers with a contract to do work or provide services for your organisation
  • Some self-employed people who have to personally carry out the work they do for you.

The gender pay gap calculation is based on the number of individual employees and not the full-time equivalent. This means that each part-time employee counts as one employee.

Apprentices, seasonal, temporary or casual employees and zero hours workers are included if they fall within the reference period created by the snapshot date.

4. Definitions

Gender Pay Gap

The gender pay gap is a measure of labour market or workplace disadvantage, expressed in terms of a comparison between males and females average hourly rates of pay. The gap can be measured in various ways and it is important to understand how the gap is being measured. The hourly rates of pay, excluding overtime are used to take account of the fact that many more males than females work full-time. Overtime is excluded because it is recognised that male employees work more overtime than female employees due to female’s caring responsibility and part-time nature of work.

Equal Pay

Equal pay means that there should be no difference in the contractual terms of a female and a male doing equal work, who both work for the same employer. For further details please refer to the Equality Act 2010.

The difference between Gender Pay Gap and Equal Pay

The most important difference between equal pay and the gender pay gap is that, equal pay requires one to scrutinise information at the level of the individual employee (to satisfy that there is equal pay for equal work). Gender pay gap reporting asks you to examine aggregate data.

Mean Gender Pay Gap

The difference between the mean hourly rate of pay of male full-pay relevant employees and that of female full-pay relevant employees.

To calculate the mean

The mean is an average of all the numbers in a dataset, that is, you have to add up all the numbers and then divide the result by how many numbers you are dealing with. To find the mean hourly rate for PCC’s full-pay relevant male employees, all the hourly rates will be added together and then divided by the total number of full-pay relevant male employees. This will give the “mean” hourly rate.

Median Gender Pay Gap

The difference between the median hourly rate of pay of male full-pay relevant employees and that for female full-pay relevant employees.

To calculate the median

The median is the numerical value which splits the top 50% and the bottom 50%. To find the median, all the hourly rates for all employees will be listed in numerical order; if there are an odd number of values, the median is the number in the middle. If there is an even number, the median is the mean of the two central numbers.

Bonus

Bonus pay means any remuneration that is in the form of money, vouchers, securities, securities options or interests in securities and relates to profit sharing, productivity, performance, incentive or commission. Non-consolidated bonuses are included. Long service awards with a monetary value are also included.

For PCC, this captures Long Service Awards and one-off honoraria payments.  Regular honoraria payments are excluded from “bonus” calculations and included in “ordinary pay”.

Mean Bonus Gap

The difference between the mean bonus pay paid to male relevant employees and that paid to female relevant employees.

Median Bonus Gap

The difference between the median bonus pay paid to male relevant employees and that paid to female relevant employees.

Bonus Proportions

The proportions of male and female relevant employees who were paid bonus pay during the relevant period.

Quartile Pay Bands

The proportions of male and female full-pay relevant employees in the lower, lower middle, upper middle and upper quartile pay bands.

Quartiles

A quartile is one of the three points that divide the population of data into 4 equal parts. In the context of gender pay gap reporting, the four quartile pay bands are created by dividing the total number of full-pay relevant employee into four equal parts. For clarification, that is not PCC Pay bands.

Measures

A positive measure, for example 18%, indicates the extent to which females earn, on average, less per hour than their male counterparts.

A negative measure, for example -18%, indicates the extent to which females earn, on average, more per hour than their male counterparts. This may happen, for example, if PCC employ a high proportion of males in low-paid part-time work, and/or the senior and higher paid employees are female.

5. The Workforce Profile

The Gender Pay Gap data supplied is correct for all staff, including school staff, in post with Portsmouth City Council on 31st March 2020 who earned their full-pay (relevant employees). At that time, there were 5,128 relevant full pay employees, which is made up by 3,671 females (72%) and 1,457 (28%) males. Out of the 5,128 relevant employees, 29 are covered by TUPE regulations (6 are male and 14 are female).

The profile of the workforce has been broken down into the proportion of full time and part time employees, whereby 1,086 (75%) of males are full time* and 371 (25%) are part time compared to 1231 (34%) of females are full time and 2440 (66%) are part time.

The profile of the workforce has been further categorised by age range. The age ranges used are based on those as determined by the ONS data.

wdt_IDAge RangeFull-time women headcountFull-time women %Full-time men headcountFull-time men %Total headcount
116 to 212261143936
222 to 291776111139288
330 to 392325320447436
440 to 492935227448567
550 to 593935532745720
660 and over1144215658270
7Total1,2311,0862,317
wdt_IDAge RangePart-time women headcountPart-time women %Part-time men headcountPart-time men %Total headcount
116 to 212267113333
222 to 29202805020252
330 to 39511877613587
440 to 4962693497675
550 to 59681907510756
660 and over3987811022508
7Total2,4403712,811

*Full time is as determined by ONS as those working 30 hours or more.

Looking at all the data for both part time and full time, our data correlates with the national data, where between the ages of 30 to 59 there are 805 men (55%) employed full time. Women however, are less likely to work full time with only 918 (25%) of 30 to 59 year olds employed full time, which is lower than last year where 62% of our male workforce worked full time compared to 31% of our female workforce. In comparison across the same age ranges (30 to 59 years old) 1818 (50%) of women are employed part time and 200 (14%) of men work part time, which is higher than last year where 10% of our male workforce and 45% of our female workforce worked part-time.

However as the majority of our workforce is predominantly female this skews the data to show that they are the higher proportion of workers across each age category compared to males, with the exception of the 60 and over age group.

The overall number of full-time men and women has decreased compared to last year with a reduction of 249 fewer employees working full time. One of the changes in relation to full-time working compared to last year is in the 16 to 21 age bracket where there are now more women than men working full time in this age range, last year there were 30 (54%) of men and 26 (46%) of women. In addition and as with last year’s report, the 60 and over age bracket is the only one with a higher proportion of males. Last year there were 82 (44%) of women and 106 (56%) of men in this age bracket. The biggest overall change is within the 30-39 age bracket where were are 139 fewer employees working full time, this is broken down as 95 fewer females and 44 fewer males compared to the previous year.

In contrast the overall number of part-time men and women has increased compared to last year with 534 more employees working part time. The biggest overall change is within the 50-59 age bracket where there were 120 more employees working part time. This is closely followed by the 40-49 age bracket where 113 more employees worked part time compared to last year.

In addition to the above age profile of the workforce, and using the same methodology as applied by the ONS, the gender pay gap has been broken down by age and full-time/part-time hours. In accordance with the ONS data, full time hours has been classed as 30 hours or more. The Gender pay gap by age full-time/part-time is based on the median salary within each data category (as per the ONS data) and uses a separate calculation for part time and full time per age range.

The data looks at the gender pay gap for people of a similar age and working pattern, unlike the statutory data which looks at the gender pay gap based on the median difference between men and women. Therefore the gender pay gap within each age bracket does not relate to the overall median figure because that is based on all relevant employees across the Council, whereas the age gender gap is based on each individual age groupings and working patterns within those age brackets.

wdt_IDAge BandsFull Time %Part Time %
116 to 2127.65-15.57
222 to 29-2.691.55
330 to 39-3.3723.91
440 to 496.0129.29
550 to 596.8727.50
660 and over3.4416.32

The table above shows that within each age bracket where there is a negative figure, for example -18%, this indicates the extent to which females earn, on average, more per hour than their male counterparts. A positive measure, for example 18%, indicates the extent to which females earn, on average, less per hour than their male counterparts.

Therefore it can be determined that female employees earn more between the ages of 22 up to age 39 for full time employees and between the ages of 16 to 21 for part time employees. As male employees get older, over 40 years old, they tend to earn more than female employees within the same age bracket when working full time, however this gap now also appears to have widened in the part time age bracket from age 30 onwards.

Last year the pay gap was -2.10% for full time workers in the 40 to 49 age bracket, now however, women working full time are earning less than their male counterparts and as such the pay gap has increased in this age group. The pay gap in the 30-39 age bracket has marginally decreased for full-time females compared to last year when the pay gap was -2.83%. By contrast the pay gap has decreased for part-time workers in the 16 to 29 age brackets meaning women are now paid more on average at this age than their male counterparts compared to last year’s pay gap figures of 0% for 16-21 and 10.18% for 22-29 year olds.

The increase in the pay gap across all ages, specifically those part time aged 30 and over, could be explained by the recruitment of new employees, particularly if more of these are female, as newer employees are likely to start at the bottom of the pay band. If an existing employee changes their working pattern from full time to part time, their hourly rate will remain the same and if they have been employed for a number of years they are likely to be at the top of their pay band through the incremental rises within the pay band compared to a new starter. In 2020 there was an increase in the number of part time males across the following age groups – 20 to 39 and 50 and over and this is reflected in the increase of the pay gap within these ages. The new vacancy filler report went live in November 2020 and will be used in future gender pay gap reporting.

Where there are pay gaps in the age ranges this may indicate the impact of taking time out of the labour market and the preference for working part time when re-joining the labour market, for example for reasons such as taking time out to have children or other caring responsibilities.

6. Key Findings

6.1 Mean Gender Pay Gap

The difference between the mean hourly rate of pay for male full-pay relevant employees and that of female full-pay relevant employees is 10.99%. In March 2019 this gap was 9.57%.

The average mean hourly rate of pay for a male was £16.93. For a female the average mean hourly rate of pay was £15.07, which results in the 10.99% difference in the mean figure reported above. This gap has slightly increased since last year due to the fact that the male average mean hourly rate of pay has seen a greater increase compared to that of females mean average hourly pay.

6.2 Median Gender Pay Gap

The difference between the median hourly rate of pay of male full-pay relevant employees and that of female full-pay relevant employees is 9.32%. In March 2019 this gap was 10.95%.

The average median hourly rate for a male was £14.16. For a female the average median hourly rate was £12.84. This result is a 9.32% difference in the median figure reported above. This gap has reduced as the male average median hourly rate has increased slightly less than the female average median salary for 2019 resulting in a slight closing of the gap.

6.3 Mean and Median Pay Gap summary

PCC’s median and mean gender pay gap compares favourably with the national figure from the ONS where the average gap for all employees, part-time and full-time is 17.3% based on data from 2019.

In addition to a job evaluation scheme, PCC has a clear policy of paying employees equally for the same or equivalent work, regardless of their gender. As such, the council:

  • provides regular job evaluation training for employees involved in undertaking job evaluation; and
  • evaluates job roles and pay bands as necessary to ensure a fair structure

The council is therefore confident that its gender pay gap does not stem from paying male and female employees differently for the same or equivalent work. Rather its gender pay gap is the result of the roles in which male and females work within the council and the salaries that these roles attract.

Across the UK economy as a whole, males are more likely than females to be in senior roles (especially very senior roles at the top of organisations), while females are more likely than men to be in front-line roles at the lower end of the organisation. In addition, men are more likely to be in technical and IT-related roles, which attract higher rates of pay than other roles at similar levels of seniority.

Females are also more likely than males to have had breaks from work that have affected their career progression, for example to bring up children. They are also more likely to work part time, and many of the jobs that are available across the UK on a part-time basis are relatively low paid. In addition new mums tend to take jobs that are nearer to home because of their caring responsibilities so this in turn may reduce their job opportunities and give them less access to productive, high-paying firms.

The gender pay gap exists within PCC as the majority (72%) of the workforce is female and predominantly a large proportion of these are employed in the lower quartile pay bands, with fewer employed at the more senior levels.

PCC’s gender pay gap is lower than the national average and this is down to a number of factors that already exist within the council:

  • The introduction of a PCC Living Wage Rate of £7.85 per hour, in November 2014, paid to all employees at the lower level of the pay structure, taking employees out of working poverty. This was increased in September 2018 to pay in line with the 2018 Foundation Living Wage rate and to continue to follow the Foundation Living Wage increases from then on. The rate for April 2020 is £9.30 per hour but will not be reflected in the Gender Pay Gap report until after April 2021 due to the snap shot date for the report.
  • PCC promotes and supports a number of flexible working policies for all employees within the organisation, irrespective of gender. These include job share, part time working and, term time working. In some areas there is also a flexibility to work from different locations.
  • Robust equal opportunities and diversity policies ensure that all employees are treated fairly and equally with a clear escalation process if an individual feels they are being treated unfairly.
  • The JESS Job evaluation scheme ensures that all jobs are evaluated to ensure equal pay for equal work across the entire authority. For example, a female support worker or female manager will be paid the same pay band as her male counterpart.

6.4 Mean Bonus Pay Gap

The difference between the mean bonus pay paid to male relevant employees and that paid to female relevant employees is 14.68%.

This has increased from last year’s gap which was -1.92%%. The reason for the change is that the overall average bonus payment made to males is higher than that of females. Males are paid on average £1,336 and females are paid on average £1,140.

6.5 Median Bonus Pay Gap

The difference between the median bonus pay paid to male relevant employees and that paid to female relevant employees is 0.53%.

This has changed significantly from last year’s figure which was -30.75%. The bonus gap between males and females has reduced significantly and can be attributed to the fact that more females received a payment and that the value of more of these payments has equalised, although there are still some differences at the higher and lower ends of the payment values.

6.6 Bonus Proportions

The proportions of male and female relevant employees who were paid bonus pay during the relevant period in the 12 months up to 31st March was 48 males (3.29%) out of a total of 1,457 males and 104 females (2.83%) out of a total of 3,671 females.

6.7 Bonus pay gap summary

The mean gender bonus gap and the median gender bonus gap for the council have changed to 14.68% and 0.53% respectively, There were a total of 104 females who received a ‘bonus’ payment compared to 48 males, which is a slight reduction on the number of females and a slight increase on the number of males who received a bonus payment compared to 2019. The 12 highest bonus payment values to females was between £2,240 and £22,397, whilst the 12 lowest bonus payment values was between £232 and £37. In comparison the highest 12 bonus payment values to males was between £1,919 to £12,809, whilst the lowest 12 bonus payment values was between £276 and £64.

The figures in the bonus proportions show that whilst there were a higher number of female employees than male employees who received a bonus payment, overall the average value of bonus payments were slightly higher for male employees.

Some honoraria payments made within PCC are used to reward outstanding contributions and the definition of “bonus” for this report captures these types of payments. As such this can skew the data and creates inconsistencies in reporting. Continuing work is needed to ensure that recording of this data is accurate in the future.

6.8 Quartile Pay Bands

The proportions of male and female full-pay relevant employees in the lower, lower middle, upper middle and upper quartile pay bands are set out in the table below.

wdt_IDGroupNumber of malesNumber of femalesTotalMale %Female %Total %
1Upper Quartile4608221,2823664100
2Upper Middle Quartile4099871,3962971100
3Lower Middle Quartile2768731,1492476100
4Lower Quartile3129891,3012476
5100

The totals differ slightly to accommodate the same hourly rate distribution across the divides.

6.9 Quartile Pay Band Summary

In order for there to be no gender pay gap, there would need to be an equal ratio of male to female in each quartile. However, within the Council, 76% of the employees in the lower quartile are female and 24% are male. The percentage of male employees increases throughout almost all the remaining quartiles, from 24% in the lower middle quartile to 36% in the upper quartile. In direct comparison the percentage of female employees decreases throughout almost all of the remaining quartiles from 76% in the lower middle quartile to 64% in the upper quartile.

7. Conclusions

While the Council’s gender pay gap compares favourably with that across the whole UK economy, it is committed to doing everything that it can to continue to reduce the gap. However, the Council also recognises that its scope to act is limited in some areas – it has, for example, no direct control over the subjects that individuals choose to study or the career choices that they make. Individuals make choices about their work/life balance and one of the trends

identified by Gender Pay Gap analysis is that female’s pay reduces at a certain age due to caring responsibilities for dependants. This is the norm for our culture. However, Portsmouth City Council ensures that individuals are able to make these choices without suffering discrimination with its various flexible working policies and culture.

The Gender Pay Gap for the “mean” and “median” categories fall below that of the national average.

There does not appear to be any benchmarking data in relation to bonus payments from ONS that will correlate directly with the calculation method defined by the Gender Pay Gap Information Regulations. Therefore, we do not know how the percentage for bonus payments compares with the national average or sector trends. However looking at the data published for 2019-20 by other local authorities, it is shown that Portsmouth is one of the few Councils who report paying any bonuses and that compared to those who do pay bonuses, Portsmouth falls within the ranges as reported by other local authorities.

In terms of the impact of the Gender Pay Gap based on age, the action plan highlights in the points in 7 and 8 actions that may assist in reducing the pay gap within certain age brackets.

8. Action Plan and Recommendations from 2019 report

Action Plan 2019Action Taken
1. To increase Managers awareness of 'unconscious bias' during recruitment and interview processes.Amendments to the Recruitment and Selection policy to include 'For all posts, careful consideration of the make-up of the decision-makers is encouraged and will be discussed at the job planning meeting. For recruitment processes with 3 or more decision-makers, it is mandatory to consider gender representation. However, if a mix of genders is not achievable, the steps taken to fulfil this requirement must be recorded and kept for 6 months after the end of the recruitment process.' An online solution for training in raising awareness of unconscious bias has been sourced and has been added to the Portsmouth Learning Gateway (our online training tool). The recruitment team will alert recruiting managers to the training and request they undertake the e-learning prior to commencing their recruitment activity.
2. Review the recruitment process and consider if it is appropriate to revise the process to anonymise the candidate's gender, age or ethnicity for the shortlisting process. This would enable a completely unbiased approach to considering candidates.Vacancy filler was introduced in November 2020 on the current recruitment portal that will enable better monitoring on gender, age, ethnicity and disability. This work will also link in with the Disability Confident Action Plan. Current marketing material used in recruitment campaigns has been reviewed and updated to promote diversity (for example using female representatives in traditionally male dominated industries)
3. Increase awareness around apprenticeship schemes to encourage more employees to improve their skills and experience giving them the opportunity to progress their career.The number of apprentices being recruited in to the Council continues to increase. Last year the Council have recently rolled out additional apprenticeships to existing staff, including Senior Leadership apprenticeships (of which 34 employees are currently undertaking this course, up from 17 in 2019). Leadership apprenticeships were introduced in 2017 and currently there are 70 employees undertaking these in addition to those on the senior leadership apprenticeship.
4. Promote the benefits of flexible working practices to employees and Managers (research conducted by Hays 'What workers want', showed that many employees (65%) who were looking for new opportunities stated that flexible working was the single most important factor for them). In addition the Council will monitor the take-up of flexible working arrangements by gender and level within the organisation and will expand this to include ethnicity.Work is being undertaken in this area to monitor flexible working requests to include informal arrangements. This work will continue for the next 12 months. Review current policies and practices around the possibility of mobile working including reviewing what technology is available that may assist/support this. Following the remote working during the pandemic a further piece of work is being undertaken to look at how we work in the future which may include more flexible/remote working.
5. Promote existing career management tools and monitor progress.The recent roll out of the Leadership Apprenticeship scheme will provide tools for staff to manage/develop their careers. This scheme will continue to be monitored over the next 12 months.
6. Promote the benefits of working for PCC, such as Apprenticeship opportunities, flexible working arrangements, diversity commitments, etc.This is now being promoted more widely in our recruitment adverts.
7. Develop a greater evidence base and widen the data collection to determine trends for the proportion of men and women who return to work after maternity, paternity, adoption or shared parental leave to resume substantive posts and those that continue in post a year after returning.Our systems are currently limited as to how far the Council is able to gather and monitor this data, but this will continue to be reviewed as far as possible. The current IT system is being replaced in April 2021 and it will be monitored for how well this information can be extracted in the future. This will also be expanded to include data on ethnicity.
8. Based on the data collected in 7 above, encourage managers to consider job redesign if there are aspects of a job that prevents or stops employees applying for them on a part-time or flexible basis.This will continue to be reviewed in conjunction with 7 above.
9. Monitor exit interview data and identify any trends to understand if one gender is leaving for common reasons compared to the other.Work is currently being undertaken to improve the current practices around exit interviews and the collation of this data and will continue to be improved over the next 12 months.
10. Develop a process to monitor starting pay both on recruitment and promotion for men and women to assess whether there are differences on starting pay as this can be one of the most common causes of the gender pay gap. This will be particularly beneficial in areas where there are skills shortages.To review whether there is a way for the Council's IT system to distinguish between recruitment and promotion.

In the meantime the starting pay on recruitment can be monitored over the next 12 months. It is hoped that with the new system this will also enable us to capture data around ethnicity.

11. Continue to monitor the allocation of additional payments that are made at managers' discretion to ensure that this is not contributing to the gender pay gap or unequal pay and address any anomalies as appropriate.A quarterly reporting system has now been implemented to monitor additional payments, with regular reports and issues being flagged to Senior Management at the earliest opportunity and as part of the on-going monitoring.
12. Monitor current pay systems and address any systematic issues so as to not cause any distortion of the data.A quarterly reporting system has been implemented to monitor our current pay systems with regular reports and issues being flagged to senior management at the earliest opportunity and as part of the on-going monitoring.
13. Continue to find ways to maximise the diversity applicants. Closer working with universities and schools to promote careers to both genders and underrepresented groups.
14. Continue to use skill-based assessment tasks in recruitment, where appropriate and continue to use structured interviews with set questions that are put to all candidates in a pre-determined order and format.
15. Roll out of Springboard programmeThis was a training programme that was offered during 2020 and consisted of a number of workshops aimed at women to enable them to develop their skills both personally and professionally.
16. Reporting on Equalities and Diversity - with the potential to create a diversity forum.A Race Equality Network for staff has now been set up. The group is now developing an action plan that will inform the steps we can all take - individually, collectively and corporately - to create an inclusive workplace and also make sure we deliver fair and equitable services to all of our communities.

In addition the council is also looking to establish networks for our staff with disabilities and for LGBT staff.

9. Action Plan 2019-20 and in addition to the actions above

  1. Changes made to our Recruitment Policy around panel diversity
  2. Following the introduction of the new IT system the Council will explore whether ethnicity pay gap data can be captured and included in the gender pay gap report. The reporting of this data will be reviewed when the Government formally introduce this reporting into legislation to ensure that the data capture complies with the legislation.

10. Timescales of achieving the action plan

The action plan will be implemented over the next 12 months and reviewed on an ongoing basis, and annually in comparison with the published results of the Gender Pay Gap report, each March. Some of the actions have been difficult to implement during 2020 due to the pandemic response and the remote ways of working.