Pay Gap Report. Kent Police 2018

Transcription

1 Pay Gap Report Kent Police 2018 Support Services Directorate, Kent Police Headquarters, Sutton Road, Maidstone, Kent ME15 9BZ Tel: Fax:

2 Foreword As an organisation we are committed to demonstrating our integrity and showing the highest levels of transparency to the public we serve. This new legislation gives us the opportunity to identify, analyse and publish any pay gaps for our police officers and police staff as part of our journey as an employer. We have made progress historically by introducing measures that improve representation among diverse groups from recruitment through to promotions and individual development as a result of conducting equal pay audits for police staff since This has enabled us to make recommendations and take any required action, improving the balance for gender, ethnicity and disability. We will continue to work hard to address any imbalance through inclusive and diverse recruitment, including offering pre-application workshops as part of our recruitment process, offering flexible working and fostering an inclusive culture. Addressing the disparity in representation at senior levels will take time, but measures are already in place to help close the current pay gap at Kent Police. I, along with my Chief Officer colleagues, am committed to providing time, resources and support to deliver against the recommendations included in this report. This report details the legislative calculations which I am confident are a true reflection of our current position for the combined pay gap figures and the separate police officer and police staff pay gap figures. I would like to focus on the qualitative detail within the report which describes the reasons for pay differences and, more importantly, what we will do as an organisation to address them as we recognise that our people underpin our success delivering our service to the public of Kent. Alan Pughsley QPM Chief Constable, Kent Police 2 P a g e

3 Contents Item Topic Page Number 1. Executive Summary 4 2. Introduction 6 3. Gender Pay Gap Calculations The Gender Pay Gap - Mean 3.2. The Gender Pay Gap - Median 3.3. The Bonus Gender Pay Gap - Mean 3.4. The Bonus Gender Pay Gap - Median 3.5. The Proportion of Males & Females Receiving a Bonus Payment 3.6. The Proportion of Males & Females in Each Quartile Pay Range 4. Ethnicity Pay Gap Calculations 4.1. The Ethnicity Pay Gap - Mean 4.2. The Ethnicity Pay Gap - Median 4.3. The Bonus Ethnicity Pay Gap - Mean 4.4. The Bonus Ethnicity Pay Gap - Median 4.5. The Proportion of White British and employees from other ethnic groups Receiving a Bonus Payment 4.6. The Proportion of White British and employees from other ethnic groups in Each Quartile Pay Range 5. Disability Pay Gap Calculations 5.1. The Disability Pay Gap - Mean 5.2. The Disability Pay Gap - Median 5.3. The Bonus Disability Pay Gap - Mean 5.4. The Bonus Disability Pay Gap - Median 5.5. The Proportion of Disabled and Non-Disabled employees Receiving a Bonus Payment 5.6. The Proportion of Disabled and Non-Disabled employees in Each Quartile Pay Range Conclusion Action Plan 25 Appendix A Equality Act 2010 (Specific Duties and Public Authorities) Regulations Appendix B Appendix C Parameters and Calculations People and Learning Strategy Appendix D HR Strategy Equality Duty Information Objectives (from the January 2018 Kent Police Statutory Duty Information Report) 38 3 P a g e

4 1. Executive Summary The introduction of the Equality Act 2010 (Specific Duties and Public Authorities) Regulations 2017 requires Kent Police to publish explicit gender related pay information in order to determine if a pay gap exists between male and female workers within the workforce. This information should be published on an organisation s website and the government s online reporting service by the 30 th March The report below provides a detailed review and analysis of data required, from which a summary document for publication can be produced. Pay information has therefore been reviewed and analysed for both police officers and police staff in the area of gender, and in addition to the regulations has also been extended to incorporate both ethnicity and disability. This follows the reporting of the previous and separate Equal Pay Audits that have been carried out internally at Kent Police since 2005, although it should be noted that the information required under the new regulations is different to that previously reported upon. In line with the new regulations the analysis is focused on the mean hourly pay, median hourly pay and bonus payments and has been used for each of these comparable groups. In line with the regulations, a combined police officer and police staff gender pay gap figure has been produced but this must be treated with some caution. The combined percentage gender pay gap is 13.6% for the mean hourly rate and 27.5% for the median hourly rate. This appears to be a high differential on first viewing, however it should be highlighted that actual pay, grading/rank structure and gender composition are very different within each of the separate police officer and police staff groups. In general terms the force tends to pay police officers at a higher rate than police staff. As the force employs 72% male officers and 61% female staff this does have a marked effect on skewing the overall figure. In particular, 54% of all police officers are male constables with an average salary of 27,258. In contrast, 47% of all police staff are females employed within Ranges A, B, C and D, with an average salary of 20,398. To support data analysis the report does concentrate on the separate staffing groups of Police Officers and Police staff in order to produce comparative data within each group. In summary the percentage gender pay gap between male and female police officers is negligible both in terms of the mean and median hourly rates of pay, showing 2.6% and 0.1% respectively in favour of male officers. This can be explained by: The mean and median rate are both within the Police Constable pay range There is a much larger proportion of male officers in the Police Constable pay range 70% of Police Constables are male Any small differences that do exist can be predominantly explained by the demographic make-up within each rank, full details of which are included within the report. 4 P a g e

5 With regards to police staff, the gender pay analysis demonstrated a larger pay gap of just over 9% in favour of males in terms of both mean and median hourly rates. Full analysis is included within the report, but in general terms the data shows that just over 60% of staff are female and that these individuals have a much greater representation in the B and C grades. The force does operate a structured grading process that is linked to the points scored under the Hay job evaluation system and where operated correctly by an organisation would provide a defence against equal pay claims regarding grading issues. The Force encompasses 6.2% police officers and police staff that are in ethnic groups other than White British and 4% police officers and police staff have a self-declared disability. These relatively small proportions, although in line with national figures, can make valid conclusions difficult in some areas of detailed analysis. Within figures comparing White British to any other ethnic group for police officers and police staff there are small percentage pay gaps in favour of the former category which is within the tolerances as set out by the Equalities and Human Rights Commission (EHRC): As a general rule differences of 5% or more, or any recurring differences of 3% or more merit further investigation. This position is echoed when comparing disabled police officers and staff with those without a disability, although it is worthy of note that there were no bonuses paid to disabled police officers and within the category of police staff, disabled staff have a higher median hourly pay rate (-2.4%). The relatively small number of bonus and honorarium payments made across all employee groups within the organisation makes it difficult to draw conclusions. In general terms there are no concerns with the distribution and amount of bonus payments made. In order to safeguard against any discriminatory practices, all discretionary payments are subject to panel scrutiny and thus fairness and equity can be ensured. Where individuals from the same group carry out police officer or police staff roles within the organisation there is no evidence of any differences in pay beyond the accepted incremental steps based on length of service. The analysis undertaken highlights a mixed picture regarding representation of the various groups, however, overall it is felt that there is a need to continue with specific recruitment and selection initiatives for underrepresented groups in order to ensure greater representation within the wider force. This should have the effect of further closing any gaps over time. As with previous Equal Pay Audits, we will continue to work with support groups to encourage people to self-declare. This will help to make comparisons more meaningful and other recommendations will be carried out over the next 12 months, utilising People Strategies to close the gaps presented where possible. We will review further comparative data in 12 months. 5 P a g e

6 2. Introduction 2.1. Background and legislative requirements On 31 March 2017 the government introduced the Equality Act 2010 (Specific Duties and Public Authorities) Regulations This places an obligation on all specified public authorities with at least 250 employees to publish a gender pay gap report. The mandatory regulations stipulate a defined set of requirements showing the difference between the median (middle value) and mean (average) pay of male and female employees. As well as setting out this statutory data we have analysed and considered the results to look at the impact of any gaps and to mitigate and reduce where possible. Full details of the requirements under the Regulations are detailed in Appendix A and parameters and calculations are set out in Appendix B. The Regulations also detail that best practice would be for organisations to consider pay gaps in relation to ethnicity and disability. These results will be utilised to assess the levels of equality in our workplace, assess the balance of our workforce at different levels and how effectively talent is being maximised and rewarded. Kent Police want to understand any impact on pay gaps and analyse the data to look for opportunities to work proactively implementing specific actions to close any identified gaps. For this purpose Gender, Ethnicity and Disability have all been included as has been the practice with all our previous equal pay audits. Nationally, the police officer workforce is more representative in terms of gender and ethnicity than it has ever been. There are 7,572 Black, Asian and Minority Ethnic (BAME) officers representing 6.3% of all police officers (compared with 4.7% in 2010 and only 2.2% in 2000). There are 35,844 female officers, representing 29.1% of all police officers (compared with 25.7% in 2010, and only 16.5% in 2000). There are no recorded figures for disability. Within Kent Police, our demographics are similar to the national picture. The aim of this report is to be open and transparent regarding our overall pay gap figures. A pay gap does not necessarily mean pay and bonuses are inappropriate or discriminatory. The analysis will seek to identify the reasons for any gaps and propose ways to reduce the same. Future reviews can begin to analyse trends to test the validity of those interventions. This data will then be utilised to develop our existing committed workforce and look for opportunities to enhance this going forwards. The desire to analyse, understand and minimise any pay gap is closely aligned to the People and Learning Strategy particularly valuing our people and demonstrating the right culture and behaviours (Appendix C). Appendix D includes the Kent Police Equality Objectives, as detailed in the Kent Police Statutory Duty Information Report 2018, and the activities supporting these objectives. We want to continue to develop our reputation for being a fair and progressive employer, attracting a wider pool of potential recruits, developing our existing people resources and enhancing productivity through a workforce that feels valued and engaged in a culture committed to tackling inequality. 6 P a g e

7 2.2. Scope and Parameters In April 2017 Essex Police and Kent Police produced a joint Project Initiation Document (PID) which detailed the requirements of the Regulations and then the corresponding objective to analyse the data presented. The PID set out the methodology for collecting data through our existing HR and payroll records via SAP. The Regulations set clear details of the pay types to be reported on and includes a definition of bonus calculations which also forms part of the pay gap analysis. Full definitions for pay calculations are shown in Appendix B. The Regulations state that we need to report based on a snapshot of data. This has been set as 31 March From the snapshot data the six calculations required under the Regulations can be undertaken to show the difference between the mean and median earnings of men and women, those with a self-declared disability and those without and those from any other ethnic background and those from a White British background. The Equality and Human Rights Commission in guidance provided for equal pay audits for large organisations suggest the following: As a general rule, differences of 5% or more, or any recurring differences of 3% or more merit further investigation. This data will be published on the Kent Police website and will also be shared on a government website by 30 March Kent Police Pay Structures Police officer pay is determined nationally through the Home Office and subject to an incremental grading system with set pay brackets. The Home Secretary is responsible for setting pay awards and changes to conditions. The police staff pay agreement was made with Unison in 1996, subject to a number of revisions, in consultation / negotiation with Unison and can be varied through local mechanisms. The annual pay award for police staff matches the percentage award for police officers and is payable on 1st September each year. The elements of pay and reward have been designed to be non-discriminatory and are applied irrespective of any protected characteristics, save for specific elements, i.e. maternity, which is in accordance with legislation. All bonuses are reviewed, managed and approved following the guidance of our Reward and Recognition Protocol. This protocol clearly defines the criteria for bonuses and aims to apply fairness and equality of access. Bonuses are awarded for work considered to be outstandingly, demanding, unpleasant or important in nature and honorariums are paid for those demonstrating exceptional performance. All applications for a bonus or honoraria payment are submitted to the Force Remuneration Panel following sign off by the relevant 7 P a g e

8 local Senior Management Team. The panel independently and consistently reviews all applications. For the purposes of the report the reference to bonuses throughout covers both bonus and honorarium payments. In addition Authorised Firearms Officers are paid a bonus under section 31 of the Police Act for rewards for diligence. This bonus is payable quarterly and each officer needs to have had a permit to carry a firearm and been available for deployment as well as maintaining operational competence during the review period. All firearms payments are approved through a local remuneration panel chaired by the appropriate Senior Manager together with support from Human Resources. Of the 3,227 police officers, 149 received a bonus payment and of the 2,388 police staff, 35 received a bonus payment. There are 13 grades in the Kent Police pay structure. Police staff progress through each grade based on service and performance. There is one group of staff within the Force Control Room (FCR) who are paid according to a different pay structure. For the purposes of this report, these individuals have been incorporated into the appropriate pay ranges within the overall police staff figures. Grades have been created by using the scores achieved through the Hay job evaluation method and grouping them into clusters so that each grade has a maximum and minimum score. Providing the Hay mechanism is used correctly it provides a defence against equal pay claims regarding grading issues. For the purposes of the report we have analysed each staffing category independently (police officers and police staff). We have also provided combined analysis. This combined analysis does not always present a true picture of any pay gap. As detailed above; the pay structures for officers and staff are very different. Police officers are typically paid a higher starting salary when they join Kent Police compared to police staff.. In comparison, although there is a wide pay range for police staff roles, there is a significant number of staff roles where the annual pay is below the starting salary of a police officer. For example, of the 2,388 police staff, 1,041 are within A, B, C, grades which represents 44% of the total. In addition, the figures are further skewed in terms of gender given that 72% of police officers are males and 61% of police staff are females. 8 P a g e

9 3. GENDER PAY GAP CALCULATIONS The following tables show the total establishment figures for police officers and police staff utilised to calculate all pay gap data, including the gender representations: Police Officers Total Number % At Rank Male Female Total Male Female Chief Constable % 0.0% Deputy Chief Constable % 0.0% Assistant Chief Constable % 50.0% Chief Superintendent % 46.7% Superintendent % 9.5% Chief Inspector % 21.3% Inspector % 22.4% Sergeant % 20.4% Constable % 29.9% Seconded Out* % 0.0% Total % 27.9% *Incudes: 2 Male Police Sergeants on secondment out of Force. Police Staff Total Number % At Rank Male Female Total Male Female Chief Officer % 0.0% Range M % 0.0% Range L % 25.0% Range K % 40.0% Range J % 66.7% Range I % 60.0% Range H % 40.6% Range G % 40.2% Range F % 49.8% Range E % 51.3% Range D % 56.3% Range C % 67.8% Range B % 80.8% Range A % 51.2% Others* % 50.0% Seconded Out** % 100.0% Total % 60.8% *Includes: 2 police staff members, Grade B, employed via the Police Federation **Includes: 1 female police staff member, Grade F, on secondment out of force. 9 P a g e

10 The following tables show the pay gap figures for: Police Officers: 3,227 Police Staff: 2,388 The overall split is: Police Officers: Police Staff: 28% female, 72% male 61% female, 39% male 3.1 The Gender Pay Gap - Mean The difference between the mean hourly rate of pay for male and female police officers and police staff expressed as a percentage: Male Female % Pay Gap Police Officers % Police Staff % Combined % For police officers the pay gap is 2.6% which is within the range of EHRC parameters. In senior ranks, of Chief Superintendent and Assistant Chief Constable, females are represented well above the 29% of overall female officers working in Kent Police. At Superintendent rank, the percentage of females is very low, 9.5%, however, this can be explained by recent promotion processes, whereby a large proportion of females were promoted to Chief Superintendent. The proportion of females in ranks at Chief Inspector and below vary between 20% and 23%, with the exception of females in the Constable rank which is 29.9% which is in line with the overall female representation. This perhaps indicates that although we are above national averages in the Constable and senior ranks (above Superintendent), work needs to continue on the development and promotion of female officers in the supervisory and managerial ranks. The mean hourly rate for female police officers is just below the top of the Constable hourly pay rate ( 18.21) and for male police officers the mean hourly rate is just above the same point. For police staff, the pay gap is 9.3% which is higher than the acceptable EHRC parameters. Upon analysis of this data, it shows that: There are 1,718 police staff employed within grades A to D (71.9%) The starting salaries are: 14,790 for grade A; 18,423 for grade B; 19,755 for grade C and 22,668 for grade D 1,125 (65%) of staff grade A to D are female 28% of all police staff are grade D (677), 56% are female 553 police staff are in grade C (375), 68% are female 10 P a g e

11 We conclude from the above that the highest numbers of police staff within the lower mean starting salary, of 18,909 are female. This compares to the starting salary for police officers that is 21,858. Females are well represented up to senior positions throughout the Organisation. However, there are significantly more females in B, C, D grade roles and this greatly affects the overall pay gap figures. When looking at middle management and above, there is a much more even distribution of males and females, with the exception of the most senior management roles, of which there are very few. In addition, there are 402 police staff in the B grades jobs, 325, (80.8%) are female. The high number of females also affects the average. These posts are lower paid and due to the high number of females at this grade, it distorts the average. It is of note, that if everyone in grades B and C are removed from the calculations, the overall hourly rate for mean calculation reduces to 4.6% which is within the EHRC tolerances. This suggests that any interventions that improve female progression will have a positive effect on the pay gap. It is worth noting that at grades E, F, I, J, the percentage of females in these roles is around 50% or above, which is encouraging. The mean hourly rate for female police staff equates to the 2 nd increment within grade E, whereas the rate for male police staff equates to just over the 4 th increment within the same grade. This overall difference is based on the higher number of females employed in Ranges A to D, and particularly when combining B and C grades, where female representation is higher. When combining police officers and police staff, the higher difference is due to the pay and gender balance between the two very different employee groups. The reasons for the differences have been explained previously. Kent Police is committed to increasing the proportion of females in management and specialist roles and this is outlined in more detail in Objective 3 of the Kent Police Equality Objectives, set out in appendix D. 3.2 The Gender Pay Gap - Median Male Female % Pay Gap Police Officers % Police Staff % Combined % The midpoint for police officers shows a nominal difference which can be attributed to the number of officers at each rank. The midpoint for both male and female officers fall in the sergeant pay bracket between the first and second increments ( ). 11 P a g e

12 The midpoint for both male and female police staff sits within grade D and at 9.2% is above the EHRC tolerances, again, this can be explained by the higher proportion of female staff employed in grades A to D. When combining police officer and police staff, the combined difference of 27.5% should be treated with caution due to the different pay and gender balance for police officer and police staff roles. This caution should be extended to all combined elements analysed below. The police officer pay scale commences higher than the police staff pay scale. Additionally, the proportion of females employed in the comparatively lower paid staff roles is much higher. 3.3 The Bonus Gender Pay Gap - Mean Male Female % Pay Gap Police Officers % Police Staff % Combined % Given the relatively small numbers of officers and staff that receive bonus payments (see section 3.5), meaningful statistical analysis is made more difficult. The information available shows that the pay gap for police officers in relation to bonuses is favoured towards males. Having undertaken analysis on the bonuses, 59% of bonuses are paid to police firearms officers. These payments are made in accordance with a range of agreed criteria and subject to audit. Firearms is a male dominated environment with a female representation of 4.5%. This would automatically lead to a gap in mean bonus gender pay. All firearms officers, regardless of hours worked, are entitled to claim 500 per quarter as long as they meet the agreed criteria. This payment was introduced from July Bonuses are awarded for creditable performance or particular distressing incidents; the allocation of bonuses is based on the allocation of officers to incidents or investigations. Males and Females both have the opportunity to be allocated to this type of work. The mean payment for females in relation to police staff is greater; on average females were paid 105 more than males. Bonuses to police staff were paid within a range from 200 to 1,500. The total number of bonuses paid to police staff is relatively small (35), of which 66% of bonuses were paid to females. Only four payments were made between 1,000-1,500 and all of these payments were made to females. All bonuses are reviewed by a remuneration panel and therefore are considered fair, equitable and consistent in accordance with an agreed set of criteria. 12 P a g e

13 3.4 The Bonus Gender Pay Gap - Median Male Female % Pay Gap Police Officers 1, % Police Staff % Combined % For police officers, the median point for females is a bonus payment of 400 which covers a payment for dealing with an unpleasant scene incident, under the arrangements set out in the reward and recognition protocol. The median point for males is a bonus payment of 1,000 which covers 2 firearms payments, whereby the officer has been in the role for the whole of the eligibility period. This figure is skewed given the higher proportion of males within the Firearms Unit who are eligible to receive the firearms bonus payment. The difference in median payments reflects that there are more payments to firearms officers than non-firearms officers and firearms officers are overwhelmingly male. Firearms payments are substantially higher than most non-firearms payments. The payment of bonuses will continue to be reviewed and monitored through the appropriate mechanisms. Initiatives to increase the proportions of female officers in the more specialist roles where higher bonus payments are more prevalent will continue. For police staff, the median point for females is a bonus payment of 300, for males this is 400. Five females and one male received the lowest amount payable ( 200), three males and one female received 500. As already indicated, four females received the highest amounts payable, 1,500. The payment is based on the types of work individuals deal with and neither gender is prohibited nor disadvantaged in the opportunity to complete the work. In order to ensure the fair and equitable payment of bonuses, each award is reviewed by the independent remuneration panel. 3.5 The Proportion of Males & Females Receiving a Bonus Payment Male Female Police Officers 6.0% 1.0% Police Staff 1.3% 1.6% Combined 4.7% 1.4% The data shows that more males are awarded bonuses in the in the police officer and combined categories which reflects the number of firearms officers within the Force, which has a higher proportion of males than females in that role (87 officers, 4 of which are female). For police staff, the data shows that a higher percentage of females than males received a bonus; with such low numbers it is difficult to draw any conclusions. 13 P a g e

14 3.6 The Proportion of Males & Females in Each Quartile Pay Range Police Officers Police Staff Combined Male Female Male Female Male Female Upper Quartile 79.2% 20.8% 51.9% 48.1% 74.8% 25.2% Upper Middle Quartile 76.1% 23.9% 47.4% 52.6% 65.9% 34.1% Lower Middle Quartile 63.7% 36.3% 28.0% 72.0% 53.8% 46.2% Lower Quartile 69.5% 30.5% 29.6% 70.4% 38.0% 62.0% For police officers the police constable rank feature in all quartiles for males and females. In the lower quartile there is a slightly greater percentage of females than males compared to the overall gender make up (28%). In the lower middle quartile there is a higher proportion of females than the overall figure. However, this proportion reduces in the upper middle and upper quartiles. The upper quartile encompasses the sergeant up to Chief Constable ranks for males and females, however, this equates to 17% of female officers above the rank of Police Constable and 25% of male officers above the rank of Police Constable. This is changing as different strategies are applied to ensure that women are more equally represented within senior ranks. This can be seen by the growing number of female officers that have reached the higher ranks. Work is ongoing to develop more women into the middle and senior ranks, as can be seen in the Kent Police Equality Objectives document in appendix D, specifically objective 3 relating to increasing the proportion of females in management or specialist roles. For police staff in grades A to D, these grades feature in all quartiles for females, whereas for males, these grades feature in all quartiles with the exception of the upper quartile. These grades are represented by 78% of females and 66% of males. In the lower quartile (grades A and B) there are significantly more females than males compared to the overall gender make up (61% of all police staff are females). In the lower middle quartile (grade C) there are proportionately more females than males. However, in the senior roles, there is a much more even split of males / females. As above, work is ongoing and is summarised in appendix D. 4. ETHNICITY PAY GAP CALCULATIONS For the purposes of this report, data has been analysed by comparing all ethnic groups against a White British comparator. Within Kent Police, based on self-declaration, there are: 94.5% White British police officers and 5.5% from any other ethnic backgrounds. For police staff this figure is: 93% White British and 7% from any other ethnic background. 14 P a g e

15 Police Officers: Total Number % At Rank White British Non White British Total White British Non White British Chief Constable % 0.0% Deputy Chief Constable % 0.0% Assistant Chief Constable % 0.0% Chief Superintendent % 0.0% Superintendent % 9.5% Chief Inspector % 2.1% Inspector % 6.1% Sergeant % 5.3% Constable % 5.6% Seconded Out % 0.0% Total Police Staff: Total Number % At Rank White British Non White Total White British Non White British British Chief Officer % 0.0% Band M % 0.0% Band L % 0.0% Band K % 0.0% Band J % 16.7% Band I % 6.7% Band H % 6.3% Band G % 4.6% Band F % 9.1% Band E % 5.9% Band D % 6.1% Band C % 7.2% Band B % 7.7% Band A % 10.5% Others % 0.0% Seconded Out % Total P a g e

16 4.1. The Ethnicity Pay Gap - Mean White British Any other % Pay Gap ethnicity group Police Officers % Police Staff % Combined % There is a 2.7% pay difference for the mean pay gap for police officers, which is within the EHRC tolerances. On further analysing percentages within each rank, this can be explained by a lower proportion of officers from any other ethnicity group in the Chief Inspector rank, the Chief Superintendent and Chief Officer ranks. The proportion of officers from any other ethnicity group in the ranks of Constable to Inspector is comparable with the overall percentage representation. In particular, it is encouraging to note that 6.1% of Inspectors and 9.5% of Superintendents are from any other ethnicity group. There is a 4.9% pay difference for the mean pay gap for police staff, which is also within the EHRC tolerances. There is no police staff representation in grade K or above from any other ethnicity group. Within grade A there are 10.5%, within grade J there are 16.7% and within the grade F there are 9.1%. In all other grades, proportions are comparable to the overall Kent Police staff figure of 7% from any other ethnicity group. The proportion of police staff from any other ethnicity group has increased since the last Equal Pay audit, from 5.86% to 7% (167), which is encouraging. The positive work of our diversity team should further aid the recruitment, development and promotion of talented individuals from other ethnicity groups which will continue to have a beneficial effect on the above figures. Further detail can be found in Objectives 1 and 2 of the Kent Police Equality Objectives that are set out in appendix D below The Ethnicity Pay Gap - Median White British Any other % Pay Gap ethnicity group Police Officers % Police Staff % Combined % The median (midpoint) for police officers shows a nominal difference which can be attributed to the number of officers at each rank. The midpoint for both those officers who have declared their ethnicity as White British and those that have declared their ethnicity as any other ethnicity group fall in the sergeant pay bracket between the first and second increment ( ), which is consistent with the male / female median pay gap. The median point for White British police staff equates to the 2 nd increment of grade D. The mid-point for staff from any other ethnicity group sits just below this. It is worth noting that the average length of service for White British staff is three years longer than that for staff 16 P a g e

17 from any other ethnicity group which explains the difference. As above, in 4.1, the positive work of our diversity teams will still continue to aid the development and promotion of talented individuals from other ethnicity groups. 4.3 The Bonus Ethnicity Pay Gap - Mean White British Any other % Pay Gap ethnicity group Police Officers % Police Staff % Combined % Within both the police officer and staff groupings from any other ethnicity group, the mean bonus paid is higher than that paid for White British police officers and staff. 4 of the 5 police officers from any other ethnicity group who received a bonus payment were firearms officers and had the maximum amount payable under the bonus scheme. Out of the White British officers, 8 were not firearms officers who received bonuses ranging from 100 to 300, which explains the difference. The payments are fair and equitable and subject to review. Bonus payments were made to 35 police staff, 4 of whom were from any other ethnicity group. The roles of those claiming a bonus came from the Criminal Justice, Crime Scene Investigation, Project Management and Finance and range from 200 to 1,500. While it appears that the gaps are outside of the EHRC tolerances, all payments made are subject to a review / remuneration panel and are fair and equitable. 4.4 The Bonus Ethnicity Pay Gap - Median White British Any other % Pay Gap ethnicity group Police Officers , % Police Staff % Combined , % The median police officer bonus payment for any other ethnicity group reflects two firearms payments. There were a higher proportion of White British officers who do not work in the Firearms Unit that received lower bonus payments and thus reduced the overall figure. The gap remains within the EHRC tolerances. The median police staff bonus payment for any other ethnicity group reflects four payments made within a wide range from 200-1,500. Whereas, for White British police staff, there were 31 payments made, within the same range, although 24 of these payments were less than 500. The representation of police staff from any other ethnicity group receiving a bonus payment is 11.4% which is above the overall representation across the force. While it appears that the gaps are outside of the EHRC tolerances, all payments made are subject to a review / remuneration panel and are fair and equitable. As detailed in the 17 P a g e

18 recommendations section of this report, work will continue to be undertaken with KMEPA (Kent Police s ethnic minority support group) and the Diversity team to identify if there are any opportunities to enhance applications from any other ethnicity group, in accordance with the Force protocol. 4.5 The Proportion of White British and employees from any other ethnicity group receiving a Bonus Payment White British Any other ethnicity group Police Officers 4.7% 2.8% Police Staff 1.4% 2.4% Combined 3.3% 2.6% The above indicates that the proportion of bonus payments to White British officers is higher than officers from any other ethnicity group. For police staff, the overall proportion of bonuses paid to staff from any other ethnicity group is higher than that paid to White British staff. The nature of the bonus payments and the formal submission and review arrangements ensures that the payments are fair and equitable. 4.6 The Proportion of White British and employees from any other ethnicity groups in each Quartile Pay Range Police Officers Police Staff Combined Any White Any White other British other British ethnicity ethnicity group group White British Any other ethnicity group Upper Quartile 94.8% 5.2% 94.0% 6.0% 94.7% 5.3% Upper Middle Quartile 95.3% 4.7% 93.3% 6.7% 94.2% 5.8% Lower Middle Quartile 93.7% 6.3% 94.3% 5.7% 94.4% 5.6% Lower Quartile 94.1% 5.9% 90.5% 9.5% 92.1% 7.9% For police officers, the split per quartile of any other ethnicity group is generally representative of the overall percentage of 5.5%. The upper quartile includes all supervisory ranks with our largest representation of officers from any other ethnicity group being at Constable rank which spans the upper middle, lower middle and lower quartiles. For police staff, the lower middle quartile spans ranges C, D and E and the upper quartile spans the Ranges I and J. As identified in section 4.1, further positive work of our diversity teams is still required in order for the upper, upper middle and lower middle quartiles to be representative of the overall figure of 7%. 18 P a g e

19 5. DISABILITY PAY GAP CALCULATIONS For the purposes of this report, data has been analysed by comparing individuals with a selfdeclared disability against those officers and staff with no declared disability. It should be noted that because of the relatively low numbers of declared disabled officers and staff, meaningful statistical analysis is difficult. Within Kent Police, there are 3.5% of police officers and 4.8% police staff with a self-declared disability. Police Officers: Total Number % At Rank Disability No Disability Total Disability No Disability Chief Constable % 100.0% Deputy Chief Constable % 100.0% Assistant Chief Constable % 100.0% Chief Superintendent % 100.0% Superintendent % 100.0% Chief Inspector % 95.7% Inspector % 99.4% Sergeant % 96.6% Constable % 96.2% Seconded Out % 100.0% Total Police Staff: Total Number % At Rank Disability No Disability Total Disability No Disability Chief Officer % 100.0% Band M % 100.0% Band L % 100.0% Band K % 100.0% Band J % 100.0% Band I % 100.0% Band H % 96.9% Band G % 95.4% Band F % 95.5% Band E % 94.5% Band D % 96.0% Band C % 94.8% Band B % 94.0% Band A % 95.3% Others % 100.0% Seconded Out % 100.0% Total P a g e

20 5.1. The Disability Pay Gap - Mean No Disability Disability % Pay Gap Police Officers % Police Staff % Combined % There is a 3.4% pay gap in favour of police officers with no disability which is within the EHRC tolerances. This can be explained by the slightly higher proportion of disabled officers within the constable rank and the lower proportion of disabled officers in the higher paid ranks above that of Chief Inspector. It should be noted that the highest proportion of officers in any rank who have declared a disability is at the Chief Inspector rank (4.3%). The mean disability pay gap rates for both police officers who have a self-declared disability and those who do not, sits either side of the top of the Constable pay point ( 18.21). There are no disabled officers at Superintendent rank and above. The majority of officers with a declared disability represent the Constable and Sergeant ranks. The small difference is explained by the higher number of officers in the lower ranks. The proportion of police staff that have a self-declared disability is 4.8%. These are represented at pay grades A to H. No police staff have a declared disability within the grades of I to M. This is a similar position to the last four years. 25% of police staff who have declared a disability are at pay grade C, 23% are at pay grade D and 21% are at pay grade B. The highest proportion of police staff at each pay grade who have declared a disability is at grade B, with 6%. This is higher than the overall representation of 4.8%. There are 115 police staff who have a self-declared disability, an improved position from 104 at the last Equal Pay audit. These relatively small numbers do make it difficult to draw meaningful conclusions, however, Objective 4 of the Kent Police Equality Objectives set out in appendix D below, illustrate the work that is being undertaken to increase the numbers of police officers and police staff that are self-declaring. The mean disability pay gap for police staff who have a self-declared disability is between the 5 th (out of 6) increment of grade D and the 2 nd (out of 6) increment for grade E, as they overlap ( 13.31), this is one increment less than the mean disability pay gap for police staff who have not declared a disability which is between the top of grade D and the 3 rd increment of grade E ( 13.76). As with police officers, the small difference is largely attributed to the higher numbers of disabled police staff within the lower grades. However, in line with previous equal pay audits there is nothing to indicate that discriminatory practices exist and the differences are within the accepted tolerances. 20 P a g e

21 5.2. The Disability Pay Gap - Median No Disability Disability % Pay Gap Police Officers % Police Staff % Combined % The midpoint for police officers shows a nominal difference which is well within the EHRC tolerances. The midpoint for both those officers who have declared a disability and those that have not falls in the sergeant pay bracket between the first and second increment ( ), which is consistent with the male / female and ethnicity median pay gap. The median pay point for police staff with a disability is higher than that of staff without a disability. The median point sits at the 2 nd increment of grade D ( 12.20). For police staff who have not declared a disability the median point sits at the 3 rd increment for grade D ( 12.49). In both instances these are within the EHRC tolerances The Bonus Disability Pay Gap - Mean No Disability Disability % Pay Gap Police Officers % Police Staff % Combined % No police officers with a disability were in receipt of a bonus. However, we do not ask if an applicant has a self-declared disability. Discussion will take place with Crystal Clear (a staff group providing support for officers and staff working within Kent Police who have a disability or care for someone with a disability) to trial an amendment to the bonus application form to try to capture this data. One police staff member with a self-declared disability received a bonus. This was from a total of 35 bonus payments made to police staff (3%). Police staff who have declared a disability have the same opportunity to apply and receive a bonus as those without; however the distributions of bonuses are minimal with stringent criteria for approval based on operational delivery or exceptional work. This is illustrated by the figures for the overall proportion of bonuses paid. It is recommended that the force should work closely with Crystal Clear and other support groups to ensure that managers understand that everybody is eligible to apply for a bonus payment irrespective of any protected characteristics. 21 P a g e

22 5.4. The Bonus Disability Pay Gap - Median No Disability % Pay Gap Disability Police Officers 1, % Police Staff % Combined % As above, there were no disabled police officers that received a bonus payment. For police staff, it should be noted that the median bonus disability pay gap is based on one payment and prohibits any meaningful analysis The Proportion of Disabled and Non-Disabled employees receiving a Bonus Payment No Disability Disability Police Officers 4.8% 0.0% Police Staff 1.5% 0.9% Combined 3.4% 0.4% As previously highlighted, Kent Police pays a relatively small amount of bonuses to both police staff and officers, making valid statistical analysis difficult. The majority of these payments are made within the firearms function and there are no officers that have selfdeclared a disability within this area. Outside of the firearms function, all other officers and staff have the opportunity to apply for bonus payments through the reward and recognition protocol and all of these applications are reviewed through a central panel comprising of operational, HR and trade union/staff association representatives. It is recommended below that the force should work closely with Crystal Clear and other support groups in educating managers in the application of the bonus payments and to enhance numbers for self-declared disability. 22 P a g e

23 5.6. The Proportion of Disabled and Non-Disabled employees in each Quartile Pay Range Upper Quartile Upper Middle Quartile Lower Middle Quartile Lower Quartile Police Officers Police Staff Combined No Disability Disability No Disability Disability No Disability Disability 96.9% 3.1% 95.5% 4.5% 97.1% 2.9% 97.1% 2.9% 94.8% 5.2% 96.2% 3.8% 96.2% 3.8% 94.6% 5.4% 94.8% 5.2% 95.8% 4.2% 95.8% 4.2% 95.7% 4.3% 3.5% of our police officers are shown as having a self-declared disability. This is representative at the lower and the lower middle quartile, where representation is above the overall figure. However, it is just slightly under this percentage for the upper middle and upper quartiles. The upper quartile includes all supervisory ranks with our largest representation of officers with a disability being at Constable rank. 4.8% of our police staff are shown as having a self-declared disability. This is representative within the lower middle and upper middle quartiles, where representation is above the overall figure. However, it is just slightly under this percentage for the lower quartile and upper quartile. The lower quartile includes Ranges A and B, the lower middle quartile includes Range C, the upper middle quartile includes Ranges D and E and the upper quartile includes Ranges E and above. In general terms, the above percentages do not indicate that there is a cause for concern, although collaborative work should continue with the appropriate support groups to encourage the recording of declared disabilities across the Force, and also to continue to review future recruitment campaigns to ensure that opportunities are inclusive and communicated to under-represented groups. 23 P a g e

24 6. Conclusion The EHRC 1 recommends that following the reporting and analysis of the pay gap data, employers should consider whether their recruitment, promotion and reward policies and approaches to flexible working are contributing to their pay gaps, and then develop an action plan to address this if needed. Kent Police have policies and processes in place that have ensured that any gap is within EHRC tolerances and we are confident that there are no equal pay issues. Over time it is anticipated that any pay gaps will be reduced if the recommendations are effected. This will be monitored and reviewed over time with each annual pay gap report in order for us to identify trends. As can be seen in appendix C, People and Learning Strategy document, there are initiatives in place to enhance the diversity of our workforce, through recruitment, promotion and retention policies. It is encouraging to note that currently almost 20% of our people are flexible workers, as this is an important part of our culture. The force offered flexible working opportunities to all police officers and staff long before the legislative requirement to do so. It is recognised that there are some pay gaps within Kent Police but these do not give a cause for concern. Previous equal pay audits that have been carried out since 2005, demonstrate that the organisation has had no concerns regarding pay in the areas of gender, ethnicity and disability for a number of years. The gender pay gap for police officers is negligible and well within the EHRC tolerances. Police staff combined with police officers gives a figure of 13.6%. However, as explained in the body of the report, this is as a result of attempting to compare two very different groupings. Notwithstanding this, there is a mean gender pay gap of 9.3% for male and female police staff. On studying the data this is largely as a result of the high proportion of females employed in roles within the grades B to D. Encouragingly, the position is changing: between 1 st April 2016 and 31 st March 2017, 130 female members of police staff were promoted out of a total of 201, which equated to 65% of all promotions. This is an increase of 5% on the previous year. For police officers, the proportion of females promoted has increased from 15 % to 26 % from the previous year. The different pay gaps for ethnicity and disability are generally below their comparator group but are within tolerances set out by EHRC. However, the force remains cognisant of the need for a positive approach towards continuously improving any such differences through the sustained use and enhancement of recruitment and development activities. Kent Police only pay a small number of bonus payments, over 50% of which are paid to the 87 police officers within firearms. This operational unit currently employs 4 female officers, 5 officers from other ethnicity groups and no disabled officers. Overall, there were no bonus 1 Source: pg P a g e

25 payments made to disabled officers and although the small proportion of bonuses paid throughout the force makes meaningful analysis difficult, this specific point will be addressed through recommendation 7, below. Any other differences were within the recommended parameters, however, Kent Police will continue to monitor and analyse trends on an annual basis in line with the legislative requirements. The recommendations in the below action plan, are closely linked with the Kent Police Equality objectives set out in the Kent Police Statutory Duty Information Report (Appendix D). Kent Police will continue to take positive action to addresses any gaps and to make continuous improvements. 7. ACTION PLAN The below action plan outlines each of the recommendations and identifies the department that will take ownership over the next twelve months. 25 P a g e

26 Recommendations No. Recommendation Lead / Owner 1. Review data in 12 months time; to compare progress and any trends in relation to Gender, Ethnicity and Disability pay Head of Employee gaps. Relations, Operational HR 2. Publicise and encourage officers and staff to self-declare any disability on SAP enabling the organisation fully understand the representation. This can be promoted through working with the Crystal Clear (Kent Police s disability support group). 3. Continue work with the force diversity experts and KMEPA (Kent Police s ethnic minority support group) to determine if any other initiatives can be undertaken to further increase the recording of declared ethnicity on SAP. 4. Work with appropriate support groups and review future recruitment campaigns and promotion processes for PO and police staff roles to maximise opportunities for any of the diverse groups in promotional roles. 5. Continue work with the Kent Network of Women (KNOW) and become actively involved (workshops, network meetings etc.) to ensure women are more equally represented in future developmental and promotional processes. 6. Continue work with Firearms and appropriate support groups to address under-representation by maximising opportunities that encourage applications for firearms roles. 7. Work with Crystal Clear to review the data of the bonus payments awarded and identify if there are any opportunities to enhance applications from individuals with self-declared disabilities. 8. Review the form used for applying for bonus payments, as to whether to include a request for information on self-declared disabilities, to help gather information on numbers of applications from both groups and whether any of these applications are unsuccessful. Diversity & Inclusion Manager Diversity & Inclusion Manager Head of Resourcing / Talent and People Development Manager Talent and People Development Manager Talent and People Development Manager Head of Employee Relations, Operational HR Head of Employee Relations, Operational HR 26 P a g e

27 APPENDIX A Equality Act 2010 (Specific Duties and Public Authorities) Regulations 2017 Who do the new obligations apply to? The Equality Act 2010 (Specific Duties and Public Authorities) Regulations 2017, with minor differences to the gender pay gap reporting regulations for the private and voluntary sectors, apply to a list of specified public authorities found in schedule 2 of the regulations: This includes government departments, the armed forces, local authorities, NHS bodies, publically funded schools and many others. They only apply if the authority has 250 or more employees on 31 March of a given year. Who counts as an employee? For the purposes of gender pay reporting, the definition of who counts as an employee is set out in the regulations and follows the definition in the Equality Act This is known as an extended definition which includes: employees (those with a contract of employment) workers and agency workers (those with a contract to do work or provide services) some self-employed people (where they have to personally perform the work) police officers and the armed forces The relevant date This is the key date that many of the details needed to carry out the calculations will come from. It is also the date from which an employer has a year to publish their gender pay report. This will always be March 31 for specified public authorities in any year where they have 250 or more employees (it s April 5 th for everyone else). How does this fit in with the Public Sector Equality Duty (PSED)? The new gender pay gap obligations have been introduced alongside the existing requirements for specified public bodies, including publishing annual information to demonstrate compliance under the PSED and publishing equality objectives every four years. The deadlines for all the publishing requirements have now been streamlined to 30 March. The Gender Pay Gap reporting requirements must be adhered to but a specified public authority can handle the process as part of their wider PSED work or equality strategy. For example, public authorities can set equality objectives which would help reduce the gender pay gap in their organisation. Organisations with over 150 employees may already be publishing gender pay gap data under the existing requirement to publish data on its 27 P a g e

28 employees. Organisations with over 250 employees must follow the methodology set out in the regulations and accompanying guidance, regardless of how this data may have been previously calculated. Other employers can prepare the calculations using the same methodology on a voluntary basis. This guide only covers the new gender pay gap reporting requirements, and does not explain in detail what is required to comply with the PSED. Further guidance on PSED reporting obligations is available at Other best practice references to support the development of a meaningful pay gap report include: Pay is one of the key factors affecting motivation and relationships at work. It is therefore important to develop pay arrangements that are right for the organisation and which reward employees fairly. Providing equal pay for equal work is central to the concept of rewarding people fairly for what they do. Employers are responsible for providing equal pay and for ensuring that pay systems are transparent, or easy to understand. A structured pay system is more likely to provide equal pay and is easier to check than a system that relies primarily on managerial discretion. - Equalities and Human Rights Commission (EHRC). However, equal pay is also good business practice. It is about treating people fairly and thus getting the best out of them. It is a necessity for any successful business or well-run organisation. - Chartered Institute of Personnel & Development, Equal Pay Guide. 28 P a g e

29 APPENDIX B Parameters and Calculations What will I have to calculate and publish? Relevant employers must follow the rules in the regulations to calculate the following information: Their mean gender pay gap Their median gender pay gap Their mean bonus gender pay gap Their median bonus gender pay gap Their proportion of males receiving a bonus payment Their proportion of females receiving a bonus payment Their proportion of males and females in each quartile pay band A written statement, authorised by an appropriate senior person, which confirms the accuracy of their calculations. However, this requirement only applies to employers subject to the Equality Act 2010 (Gender Pay Gap Information) Regulations 2017 Steps for extracting essential information STEP 1: Full list of relevant employees from SAP then establish full-pay relevant employees (Relevant employees are all employees employed by the employer on the snapshot date of a given year, except for partners.) (This term includes full-pay relevant employees and also other employees employed on the snapshot date but on less than full pay because of leave.) STEP 2: STEP 3: Identify for each full pay relevant employee if: - Male or Female - Self-Declared Disability - Self-Declared Ethnicity - Extract a list of all bonuses received in the relevant bonus period for all relevant employees and full-pay relevant employees. The bonus period is a twelve month period that ends on the snapshot date. STEP 4: Record all ordinary pay received in the relevant pay period for fullpay relevant employees only. 29 P a g e

30 (Ordinary pay is defined in regulation 3. It includes basic pay, allowances, pay for piecework, pay for leave and shift premium pay. It only includes money payments, so anything that is not money (such as benefits in kind or securities) is excluded. Gross amounts should be used after salary sacrifice.) Ordinary pay does not include pay related to overtime, redundancy or termination of employment, pay in lieu of annual leave or pay which is not money. As well as actual overtime pay, payments such as allowances earned during paid overtime hours (to the extent that employers can clearly identify them) should be excluded from ordinary pay. The relevant pay period is the pay period within which the snapshot date falls. In practice, this means the pay period in which March 31 st falls (for employers subject to the Specific Duties Regulations) STEP 5: Record the weekly working hours for full-pay relevant employees only. STEP 6: Record the hourly pay for full-pay relevant employees only. (To find the hourly pay, first add the employee s bonuses identified in 4 above, to their ordinary pay identified in 5 above. Next, multiply this amount by the appropriate multiplier. This is 7 divided by the number of days in the pay period. This provides a weekly pay figure for the relevant pay period. Finally, divide this amount by the employee s number of weekly working hours identified in 6 above. Keep in mind that the regulations specify that where periods are calculated in months, a month is treated as having days, and where periods are calculated as a year, a year is treated as having days.) The Calculations These calculations make use of two types of averages: 30 P a g e

31 A mean average involves adding up all of the numbers and dividing the result by how many numbers were in the list. A median average involves listing all of the numbers in numerical order. If there is an odd number of results, the median average is the middle number. If there is an even number of results, the median will be the mean of the two central numbers. Using these two different types of average is helpful to give a more balanced overview of an employer s overall gender pay gap: Mean averages are useful because they place the same value on every number they use, giving a good overall indication of the gender pay gap, but very large or small pay rates or bonuses can dominate and distort the answer. For example, mean averages can be useful where most employees in an organisation receive a bonus but could be less useful in an organisation where the vast majority of bonus pay is received by a small number of board members. Median averages are useful to indicate what the typical situation is i.e. in the middle of an organisation and are not distorted by very large or small pay rates or bonuses. However, this means that not all gender pay gap issues will be picked up. For example, a median average might show a better indication of the middle of the road pay gap in a sports club with a mean average distorted by very highly paid players and board members, but it could also fail to pick up as effectively where the pay gap issues are most pronounced in the lowest paid or highest paid employees. For the results of the calculations: A positive percentage figure (which almost all organisations are likely to have) reveals that typically or overall, female employees have lower pay or bonuses than male employees. A negative percentage figure (which some organisations may have) reveals that typically or overall, male employees have lower pay or bonuses than female employees. A zero percentage figure (which is highly unlikely, but could exist for a median pay gap where a lot of employees are concentrated in the same pay grade) would reveal no gap between the pay or bonuses of typical male and female employees or completely equal pay or bonuses overall. Kent Police Analysis of inclusion for Ordinary Pay Pay Basic pay - Allowances - Car allowance - SE allowance - Housing allowance 31 P a g e

32 - Weekend Working Enhancement - Shift allowance - Travel allowance - Fringe allowance - Market supplements Exclusions - Maternity pay (unpaid) - Paternity (paid) - Sick pay (long term) - Dependants leave (PSE) - Adoption leave - Career break Information to be included in GPG Report The difference between the mean hourly rate of pay for male and female employees expressed as a percentage The difference between the median hourly rate of pay for male and female employees expressed as a percentage The difference between the mean bonus pay paid to male and female employees over the 12 months ending 5 April expressed as a percentage Only full pay employees are included in this calculation (see 9 g). The percentage must be calculated: (A-B) x100 A Where A is the mean hourly rate of pay of all male full-pay relevant employees; and B is the mean hourly rate of pay of all female full-pay relevant employees The percentage must be calculated: (A-B) x100 A Where A is the median hourly rate of pay of all male full-pay relevant employees; and B is the median hourly rate of pay of all female full-pay relevant employees The percentage must be calculated: (A-B) x100 A Where A is the mean bonus pay paid during the relevant period to all male relevant employees who were paid bonus pay during that period; and B is the mean bonus pay paid during the relevant period to female relevant employees who were paid bonus pay during that period Relevant period in this provision means P a g e

33 months ending with the snapshot date The difference between the median bonus pay paid to male and female employees over the 12 months ending 5 April expressed as a percentage The percentage must be calculated: (A-B) x100 A Where A is the median bonus pay paid during the relevant period to all male relevant employees who were paid bonus pay during that period; and B is the median bonus pay paid during the relevant period to female relevant employees who were paid bonus pay during that period Relevant period in this provision means 12 months ending with the snapshot date The proportions of male and female employees who were paid bonus pay over the 12 months ending 5 April The proportion of male relevant employees who were paid bonus pay to be expressed as a percentage as follows: (A-B) x100 A Where A is the number of male relevant employees who were paid bonus pay during the relevant period; and B is the number of male relevant employees The proportion of female relevant employees who were paid bonus pay to be expressed as a percentage as follows: (A-B) x100 A Where A is the number of female relevant employees who were paid bonus pay during the relevant period; and B is the number of female relevant employees Relevant period in this provision means 12 months ending with the snapshot date The proportions of male and female employees in quartile pay bands Step 1: determine the hourly rate of pay for each male and female employee and rank from lowest to highest paid Step 2: divide the employees into four, each section comprising an equal number of employees to determine the lower, lower middle, upper middle and upper quartile pay bands Step 3: the proportion of male employees 33 P a g e

34 within each quartile band must be expressed as a percentage of the employees within that band as follows: (A-B) x100 A Where A is the number of male employees in a quartile pay band; and B is the number of relevant employees in that quartile pay band Step 4: the proportion of female employees within each quartile band must be expressed as a percentage of the employees within that band as follows: (A-B) x100 A Where A is the number of female employees in a quartile pay band; and B is the number of relevant employees in that quartile pay band 34 P a g e

35 APPENDIX C 35 P a g e

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